DOCKET NO. TABLE OF CONTENTS

Transcription

1 DOCKET NO. TEXAS-NEW MEXICO POWER COMPANY S REQUEST FOR APPROVAL OF AN ADVANCE METERING SYSTEM (AMS) DEPLOYMENT AND AMS SURCHARGE Before the Public Utility Commission Of Texas TABLE OF CONTENTS Description Page Table of Contents 1 Petition and Application 2-7 Attachments A through F 8-46 Testimony and Exhibits of Stacy R. Whitehurst Testimony and Exhibits of Gary J. Kessler Testimony and Exhibits of F. Allan Burke Testimony and Exhibits of Kimberly Morris Testimony and Exhibits of Michael D. Montgomery Testimony and Exhibits of Henry E. Monroy 1

2 DOCKET NO. TEXAS-NEW MEXICO POWER COMPANY S REQUEST FOR APPROVAL OF ADVANCED METERING SYSTEM (AMS) DEPLOYMENT PLAN AND REQUEST FOR AMS SURCHARGES PUBLIC UTILITY COMMISSION OF TEXAS TEXAS-NEW MEXICO POWER COMPANY S PETITION AND APPLICATION NOW COMES Texas-New Mexico Power Company (TNMP) and file its Request for Approval of Advanced Metering System (AMS) Deployment Plan and Request for AMS Surcharges. In support thereof, TNMP respectfully shows as follows: I. Jurisdiction Texas-New Mexico Power Company is a transmission and distribution utility (TDU) as that term is defined in Section (19) of PURA. 1 The Commission has jurisdiction over TNMP and over the subject matter of this proceeding under PURA II. Representatives documents is: TNMP's authorized representative for service of pleadings, motions, orders, and other Mr. Stacy Whitehurst Supervisor of Regulatory Policy Planning Texas-New Mexico Power Company 225 E. John Carpenter Freeway Suite 1500 Irving, Texas Tel: Facsimile: Stacy.Whitehurst@pnmresources.com 2009). 1 Public Utility Regulatory Act (PURA), TEX. UTIL. CODE ANN through (Vernon 2007 & Supp. TEXAS-NEW MEXICO POWER COMPANY S PETITION AND APPLICATION FOR AMS APPROVAL -1-2

3 TNMP s authorized legal representative is: Scott Seamster Corporate Counsel PNMR Services Company 225 E. John Carpenter Freeway Suite 1500 Irving, Texas Tel: Facsimile: Scott.seamster@pnmresources.com III. Relief Requested by Texas-New Mexico Power Company Through this petition and application, in accordance with P.U.C. SUBST. R (d), TNMP requests approval of the proposed Advanced Metering System Deployment Plan attached hereto as Attachment A. TNMP s Statement of AMS Functionality in accordance with P.U.C. SUBST. R (d)(3) is Attachment B hereto. Under the advanced meter deployment plan, TNMP will provide full deployment of advanced meters to approximately 240,000 retail electric customers over the period In addition, pursuant to PURA (k), TNMP requests approval of an AMS Surcharge tariff to recover the reasonable and necessary costs it will incur under the deployment plan for the full deployment of advanced meters to residential and non-residential customers in its retail electric service area, except for those customers who have interval demand recording (IDR) meters or take unmetered service. TNMP's proposed AMS Surcharge tariff is set forth in Attachment C hereto. TNMP requests that the requested AMS Surcharge tariffs become effective with the earlier of either the 1 st billing cycle of the next month following a final order, or November 1, 2010, and be in effect for twelve (12) years. IV. Persons Affected The relief sought by TNMP will affect all retail electric providers (REPs) serving residential and non-residential customers in TNMP s service areas, except those who have IDR meters or take unmetered service. Retail end-use customers may be affected, depending on the TEXAS-NEW MEXICO POWER COMPANY S PETITION AND APPLICATION FOR AMS APPROVAL -2-3

4 actions taken by the REPs to pass the AMS surcharges through to the end-use customers they serve. V. Notice TNMP proposes that notice be provided: (1) by mailing notice, in the form attached as Attachment D, to all REPs doing business in Texas listed on the Commission's website as of the date of this petition and application; (2) by publishing notice, in the form attached as Attachment E, for two weeks in newspapers having general circulation in each county in TNMP's service areas; and, (3) by serving a copy of this petition and application on each party to TNMP s most recent base rate case, Docket No Although the Commission has exclusive jurisdiction over this proceeding, TNMP will also provide notification of this petition and application to all municipalities in TNMP s service areas. VI. Texas-New Mexico Power Company s Filing In addition to this petition and application and the attachments hereto, TNMP submits the direct testimonies and exhibits of the following witnesses in support of the relief which it seeks: Stacy R. Whitehurst, Supervisor of Regulatory Policy and Planning for TNMP in the Regulatory Policy Department at PNMR Services Company o provides an overview of the filing made by TNMP pursuant to P.U.C. SUBST. R and to introduce TNMP s witnesses and the subject matters of their testimonies; o describes the objectives sought through the installation of an AMS system; o provides an overview of the AMS technology being deployed at TNMP; and, o provides an explanation of certain McKinsey Model Assumptions. Allan Burke, Director Retail Electric Provider (REP) Relations Department of Texas-New Mexico Power Company o presents TNMP s deployment schedule and the effects to TNMP Operations. 2 Application of Texas-New Mexico Power Company for Authority to Change Rates, Docket No TEXAS-NEW MEXICO POWER COMPANY S PETITION AND APPLICATION FOR AMS APPROVAL -3-4

5 Gary Kessler, Domain Architect for Smart Grid for PNMR Services Company o presents the technology solutions that are required for TNMP to successfully implement an AMS solution. Kim Morris, Director of Architecture within the Business Technology Services Department of PNMR Services Company o presents the back office budget requirements and assumptions to successfully implement an AMS solution. Henry Monroy, Director, Utility Accounting for PNMR Services Company o presents the accounting requirements and assumptions to successfully implement an AMS solution. Michael Montgomery, Regulatory Project Manager in the Cost of Service and Pricing Group in the Regulatory Policy and Planning Department at PNMR Services Company o presents the McKinsey model and cost allocation and rate design. The evidence sponsored by the above witnesses establishes that TNMP s deployment plan meets the requirements of P.U.C. SUBST. R ; the AMS Surcharges requested by TNMP meet the requirements of P.U.C. SUBST. R (k); and, the waivers sought by TNMP meet the requirements of P.U.C. SUBST. R (g)(3). VII. Request for Protective Order Certain of the materials pertaining to TNMP s AMS initiative and the implementation of the deployment plan either, (1) consist of confidential and commercially sensitive information, the public release of which would harm the Applicant and adversely affect the costs of providing advanced meters, or (2) consist of proprietary information of vendors with whom the Applicant has contracted in order to achieve the AMS objectives and which TNMP is contractually obligated to maintain as confidential. TEXAS-NEW MEXICO POWER COMPANY S PETITION AND APPLICATION FOR AMS APPROVAL -4-5

6 TNMP, accordingly, requests the issuance of a Protective Order under P.U.C. PROC. R (c) in the form attached as Attachment F and the adherence by all participants to this proceeding with such protective order. VIII. Proposed Procedural Schedule In order to ensure that this proceeding can be processed as expeditiously as reasonably possible, the Applicants respectfully request that the Commission not refer this proceeding to the State Office of Administrative Hearings and, instead, retain full jurisdiction over this proceeding. Moreover, in furtherance of as expeditious a proceeding as reasonably possible, TNMP respectfully requests that the Commission adopt the following procedural schedule for this proceeding: TNMP Filing Wednesday, May 26, 2010 Intervention Deadline Friday, July 09, 2010 Intervenor Testimony Wednesday, July 21, 2010 Staff Testimony Wednesday, July 28, 2010 Intervenor Rebuttal/TNMP Rebuttal Wednesday, August 04, 2010 Hearing Wednesday, August 11, 2010 Initial Briefs Wednesday, August 18, 2010 Reply Briefs Wednesday, August 25, 2010 The objective of the proposed schedule is to enable the Commission to issue a final decision in this proceeding by October 23, Such issuance of a final order is necessary for TNMP to be able to initiate orders for equipment with the vendor and make the necessary modifications and enhancements to the IT systems so as to be in the position to proceed with the initial roll-out of advanced meters beginning on or about January 1, 2011, as contemplated in the deployment plan. 3 P.U.C SUBST. R (d)(7) contemplates commission approval or rejection of the Deployment Plan within 150 days of a request of approval. TEXAS-NEW MEXICO POWER COMPANY S PETITION AND APPLICATION FOR AMS APPROVAL -5-6

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8 TEXAS-NEW MEXICO POWER COMPANY'S ADVANCED METERING SYSTEM DEPLOYMENT PLAN ATTACHMENT A 1. Purpose. The purpose of this document is to present the Texas-New Mexico Power Company s (TNMP) plan for deploying an advanced metering system in its respective service areas (AMS Deployment Plan) The information required by P.U.C. SUBST. R (d)(4) is contained in this document. 2. Advanced Meter Technology. The advanced meter technology that TNMP plans to deploy will provide or support the minimum system features indentified in P.U.C. SUBST. R (g)(1) adopted by the Public Utility Commission of Texas (Commission). The specific features of the proposed advanced metering technology are described in the following subsections (a) through (k): (a) The advanced meters TNMP plans to deploy can be read automatically and remotely. (b) The advanced meters TNMP plans to deploy will utilize a two-way communication system. The communications technology that TNMP plans to use is described in Section 3 below. (c) TNMP is proposing to deploy approximately 240,000 of SmartSynch s AMI Intelligence smart metering solution which features a communications module that is integrated into the several vendors electricity meters, such as GE I-210+c, Elster s REX, Landis+Gyr Focus. TNMP will be utilizing GE s I-210+c meter for the AMS deployment. The I-210+c SmartMeter can communicate with C12.21 head-end systems (such as MV-90) and complies with ANSI C12.19 protocols for data storage. At time of deployment, all SmartSynch Meters deployed will transmit data using C12.22 ANSI communications. Those meters in the field that are not C12.22 compliant will be upgraded from C12.19 via an over-the-air firmware update. (d) The I-210+c SmartMeter is a single phase electronic watt-hour meter for use in residential and light commercial service locations. The I-210+c s key features include Time of Use, Demand and Load Profile, Power Quality and Low Voltage Monitoring, Remote Connect/Disconnect, Remote Meter Programming, and C12.19/C12.21 compatibility. GE s I-210+c SmartMeter also will include a ZigBee Smart-Energy compliant wireless component for in-premise HAN communications. Badger ORION wireless component for multi-utility gas and water reads are optional. (e) The meter construction and two-way communications capability will enable TNMP to process remote connects and disconnects of power service. The advanced meters have the ability to measure, store, and report both energy inflows and outflows, as necessary for net metering purposes. Deployed meters will be four channels at a minimum. This data will be available in 15-minute intervals and provide approximately 2,880 meter reads per month as opposed to the historic single read per month. Additionally, they have the capability to provide direct, real-time access to customer usage data subject to v.1 1 8

9 TNMP -Advanced Metering System Deployment Plan the limitations and priorities of the associated network infrastructure (e.g., the amount of data that can be handled by the back-office systems and the data traffic for HAN communications). (f) These meters will also be enabled to operate with a customer s HAN device through the ZigBee wireless component. Communication with HANs allows for increased demand response and demand side management by providing pricing signals to customers, controlling selected appliances and their usage profiles, and providing energy consumption information to consumers via the web portal (described in more detail below) or in-home monitors. They can also support a more robust and efficient OMS and coordination with distribution automation by providing voltage threshold signals to the distribution system. The ZigBee protocol will be Smart Energy compliant. (g) The single phase self-contained advanced meters to be deployed that are rated at 200 amps or less contain a service switch that can be used to remotely connect or disconnect service via the advanced meters system (AMS) network. The advanced meters to be deployed have the capability of load-side voltage detection, and the service switch will not close if load-side voltage is detected. The service switch also has the capability to open when a configured current limit level is exceeded. The service switch will have the capability to reconnect after a configurable amount of elapsed time. (h) TNMP s AMS has the capability to time-stamp meter data. Periodic meter reading data is consistent with American National Standards Institute ( ANSI ) C12.19 file table standards accepted by the Electric Reliability Council of Texas (ERCOT), and can be time (hour, minute, and second) and date stamped. (i) TNMP s proposed advanced meter will have the capability to interact with devices inside a customer s premise. The ZigBee HAN communication device inside the advanced meter will have the capability to communicate with a HAN device in the home for sending pricing signals, supporting demand response, pre-payment options and other communications as specified in the implementation phase of Substantive Rule (j) The AMS installed by TNMP will have the capability to reconfigure and upgrade the advanced meters over the communication networks, as technology advances, and in TNMP s determination, the upgrade becomes economically feasible. TNMP will comply with market notification requirements in P.U.C. SUBST. R (g)(5). TNMP s AMS will have the capability to provide firmware upgrades for the HAN communication device in the advanced meter, which will allow changes to be implemented as industry standards are modified or added. (k) At this time, TNMP is not aware of any issue that would restrict the ability to upgrade these minimum capabilities as technology advances. For more information on the associated meter technology, see the TNMP s Statement of AMS Functionality, Figure 1 and Attachment B V.1 2 9

10 TNMP -Advanced Metering System Deployment Plan 3. Communication Technologies. TNMP s core meter communications will be based on the existing cellular communications network provided by AT&T. Current tests by these providers have indicated 96% coverage for TNMP s service territory, and subsequent discussions have resulted in a commitment by the cellular providers to guarantee functional communications for 100% of the customers receiving smart meters. In areas where AT&T is lacking coverage, TNMP s meter technology allows for us of alternative cellular carriers that may have better coverage. In 2009, to have shovel ready project in order to meet the requirements of the Department of Energy Smart Grid Grant Application, TNMP expanded the pilot program to nearly 10,000 meters. TNMP s service territory is extremely geographically diverse and dispersed. The geographic diversity, coupled with TNMP s smaller customer base (relative to other primary ERCOT participants), challenges the feasibility of a large capital investment for a communications infrastructure. The communications infrastructure required for the Company s service territory would be prohibitively expensive for the customer base, and consequently, cellular communication represents a cost-effective solution to smaller utilities with a geographically dispersed rural customer base. This approach is not unique in terms of technology, and represents a low-risk technological solution to Advanced Metering. For many years, Commercial and Industrial (C&I) meter reading has been done using the Plain Old Telephone System (POTS) by having a data collection system call each meter for a reading, then collecting the information and passing it on to the back-office. This has always been done for major commercial customers with complex billing requirements such as Time of Use, Critical Peak Pricing and Interval Pricing. TNMP s AMS solution is designed to utilize the technology created for C&I meters, simplify it, and move it to a residential form factor and small commercial application, lower the meter cost, and insert cellular telephony in place of the POTS communications. Key points to note regarding TNMP s cellular communications solution are: (A) The solution utilizes TCP/IP protocol from the back-office to the meter and/or smart grid device endpoints; (B) Reliance on Public Wireless Networks of any technology; specifically TNMP s solution will utilize GPRS and HSPA for most service areas; (C) Home Area Networks can use either the ZigBee OR 6LoWPAN protocols; (D) Uses IEEE standards throughout the network from back-office to device end-point; (E) Highly secure because it uses device level encryption (AES 256), application level encryption and network level security in addition to a private network on the cellular carrier via Application Private Network (APN). Additionally this technology is the only technology being used by DOD for AMI on existing military bases and; V

11 TNMP -Advanced Metering System Deployment Plan (F) Bandwidth extensibility without capital investment by the utility. In the ERCOT market, most of the utilities have chosen to implement a different approach as the majority of their customers are in urban and suburban areas. Specifically, all of the major utilities have chosen to implement private communications networks versus using public networks. With a larger customer base to spread out the costs, large utilities have the economies of scale that help keep AMS infrastructure charges lower than TNMP on a per customer basis. The three major TDSPs have chosen two different approaches: mesh/tower and tower based systems. Both solutions are being built on private, utility-owned networks that will be funded by the consumer through rate increases and surcharges. 4. Systems Developed During the Deployment Period. i) Back-office Systems Two back-office systems are integral to the deployment of TNMP s smart grid program: outage management system and the meter data management system is described in more detail below: (1) Outage Management System (OMS). TNMP s current plans are to install Milsoft Utility Solutions DiSpatch outage management system. The DiSpatch Outage Manager is a component of the DiSpatch Client and provides a tabular view of the outages. The Outage Manager is used to modify and review outage information and access complete outage history. Milsoft s DiSpatch tool provides many capabilities which will include: Trouble Call Management interacting with IVR to automatically interact with effected customers, communicate accurate caller information to dispatchers, and maintain call histories; Outage Management predict outage points, dynamically react to multiple outages in real-time, communicate outage circuit information to dispatchers, and dynamically process restorations; Reporting compile and report outage statistics in customized reporting formats; and, Crew Management perform crew assignments, identify required truck types, and automatically determine primary crew. DiSpatch will be tightly integrated with TNMP s existing circuit load flow analysis tool ( WindMil ) which is also a Milsoft product. The OMS will utilize engineering maps and data through WindMil in assisting with the management of outages (2) Meter Data Management System (MDMS). TNMP will be implementing Itron s EE MDMS solution. At a minimum, MDMS provides a database repository and utility-specific business logic to: V

12 TNMP -Advanced Metering System Deployment Plan Automate and streamline the complex process of collecting meter data from multiple meter data collection technologies; Evaluate the quality of that data and generate estimates where errors and gaps exist; and Deliver that data in the appropriate format to TNMP s billing systems. The MDMS will pre-process granular interval meter data at large volumes very quickly. AMS now has every meter in the entire meter population bringing back complex billing data in 15 minute intervals. The MDMS performs a number of tasks; it will: Aggregate and pre-process this granular interval data; Perform data validation, computation and editing of missing data; and Create billing ready data for Banner. As TNMP smart meters are deployed, the MDMS will handle the storage and distribution of non-billing data and messaging such as two-way commands, outage alarms, tamper alarms and demand response events. ii) Customer Education As an integral part of the Company s AMS deployment plan, TNMP is implementing a customer education program that is designed to reach customers who will be receiving an advanced meter. Through this program, TNMP is seeking to educate those customers about the benefits of advanced metering technology and how this capability can help customers save energy and money, and help provide better system reliability. TNMP s customer education program is centered on various customer outreach tools, such as community events, presentation materials (chamber meetings or city council forums), and electronic communications. Customers will receive several information sources that will provide an overview of TNMP and its role in the community, TNMP s use of technology to improve electric delivery and reliability, and information about what the advanced meter means for consumers. 5. Timeline for Web Portal Development. TNMP is working with other Transmission and Distribution Service Providers (TDSPs) in ERCOT to implement a common AMS web portal under development in Project No In the event the common web portal is not available for TNMP s initial AMS deployment, TNMP will provide alternate methods of delivery for the AMS data, which will include access to the data from TNMP s secure web site or other secure web interfaces. 6. Deployment Schedule by Specific Area (geographic information). (a) On April 16, 2009, TNMP selected the SmartSynch/AT&T SmartMeter solution for a 10,000 unit point-to-point deployment to residential customers throughout the utility s Texas market. TNMP s decision was spurred by the successful performance of five SmartSynch system pilots deployed during the V

13 TNMP -Advanced Metering System Deployment Plan last 14 months in Clifton, Lewisville, Texas City, Dickinson, and Brazoria, Texas. The pilots supported the collection of billing reads, remote service connect/disconnect capabilities and real-time event alarm notification. TNMP s deployment of this point-to-point deployment will place approximately 400 meters in Lewisville and Fort Stockton. The remaining meters will be installed in the Gulf Coast service area. The installation on these 10,000 meters was completed at the beginning on January (b) (c) (d) TNMP s deployment of advance meters will align with TNMP s service territory designations as described in the ERCOT Retail Market guide for working disconnect for non-pay. In the retail market guide, TNMP s service territory is broken into the following geographic designations: Gulf Coast, Central Texas, West Texas and North Central. For TNMP s deployment, these four geographic designations will be used; except the North Central Texas area will be separated into two separate areas. The first area is the Greater Lewisville area, which contains the Cities of Lewisville and Coppell. The second area will be all remaining cities in the North Central service area. TNMP will designate these two subareas of its North Central service area as Lewisville and North Texas throughout the AMS deployment. TNMP will complete a full deployment in all service territories by the end of year TNMP plans to install approximately 44,000 by the end of 2011, approximately 48,000 by the end of 2012, approximately 46,000 by the end of 2013, approximately 42,000 by the end of 2014, and approximately 35,000 by the end of Figure 2 provides a detailed listing of the areas and the quarters in which the TNMP plans to deploy the proposed AMS. It may become necessary to revise this schedule and sequence over the course of the deployment of AMS due to changing circumstances. Should that be the case, TNMP will report on any changes to this proposed schedule and sequence in its monthly progress reports that will be filed pursuant to P.U.C. SUBST. R (d)(9). 7. Reports. (a) Commencing with the approval of this AMS Deployment Plan by the Commission, a monthly status report meeting the requirements of P.U.C. SUBST. R (d)(9) will be filed with the Commission within 15 days of the end of the month to which it applies during the AMS deployment period. TNMP will notify all certified REPs of the availability of the report through the standard market notice requirements. The monthly progress report will include the number of advance meters installed by ESI ID, variations in the AMS Deployment Plan, significant problems TNMP has experienced, the number of advanced meters replaced as a result of the AMS problems, and any status of AMS feature Deployment V

14 TNMP -Advanced Metering System Deployment Plan (b) (c) (d) Upon request by a REP, TNMP will provide a report to the requesting REP stating the estimated cost and schedule for providing a non-standard advanced meter or non-standard advanced meter feature. TNMP will, jointly with other TDSPs involved in developing the common portal, hire an independent, third party to conduct a security audit of the common AMS web portal requirements as the development of the common web portal begins and will provide the results of that audit to the Commission in a compliance filing for the reporting. Additionally, TNMP, within two years after initially providing commercial AMS service, will engage an independent security auditor to conduct an audit of the Company s mechanisms for customer and/or REP access to meter data consistent with P.U.C. SUBST. R (j)(3). TNMP will provide annual reports to the Commission, which shall include actual costs spent to date in deploying the AMS, the actual net operation cost savings, and the variances from projections, to determine the surcharges authorized by the Commission. The first such report will be filed by February 1, 2012, and cover the period of the first year of the deployment and in which the surcharges have been in effect. 8. Schedule for Deployment of Web Portal Functionalities. As mentioned previously, TNMP has completed a 10,000 meter pilot for Until the functionalities associated with the common Web Portal under development in Project No are available, TNMP will provide alternate methods of delivery for the AMS data, which will include access to the data from TNMP s secure web site or other secure web interfaces V

15 TNMP -Advanced Metering System Deployment Plan FIGURE 1 Smart Grid Program AMS Elements V

16 FIGURE 1 cont v

17 FIGURE 2 GULF COAST LEWISVILLE NORTH TEXAS CENTRAL TEXAS WEST TEXAS GROWTH TOTAL Pilot & ,804 2, ,100 Q1 10, , Q2 11, ,927 Q3 11, ,905 Q4 11, ,209 Total 44, ,707 47,967 Q1 11, , Q2 12, ,455 Q3 12, ,707 Q4 11, ,394 Total 48, ,975 50,267 Q1 11, , Q2 5,079 7, ,573 Q3-12, ,494 Q4-11, ,494 Total 16,503 30, ,975 48, V

18 GULF COAST LEWISVILLE NORTH TEXAS CENTRAL TEXAS WEST TEXAS GROWTH TOTAL Q1-8,391 2, , Q , ,972 Q , ,765 Q ,875 7, ,572 Total - 8,391 26,325 7,203-1,976 43,895 Q , , Q , ,836 Q , ,040 Q , ,263 Total ,399 16,301 2,004 36,704 Grand Total 119,859 40,592 26,326 25,696 16,301 11, , V

19 ATTACHMENT B TEXAS-NEW MEXICO POWER COMPANY'S ADVANCED METERING SYSTEM STATEMENT OF FUNCTIONALITY 1) Purpose. The purpose of this document is to present Texas-New Mexico Power Company ( TNMP ) Statement of AMS Functionality. The information required by P.U.C. SUBST. R (d)(3) is contained in this document. 2) Technological requirements. The advanced meter system described in TNMP s AMS Deployment Plan submitted to the Commission as Attachment A meets the requirements specified in P.U.C. SUBST. R (g). 3) Service Area Variances between Technology and Meter Functions. TNMP s plan is to use a two-way communication system over public wireless, IP-based Smart Grid technology for its AMS. TNMP reserves the right to deploy alternative technologies or file a waver in areas where sufficient wireless coverage does not exist. 4) Request for Waivers. There are certain individual retail customers and service types where exceptions to the AMS requirements contained in Substantive Rule are appropriate. In its Request for Approval of Advanced Metering System Deployment Plan and Advanced Metering System Surcharge, TNMP is requesting a waiver to relieve the Company of the obligation of installing an advanced meter that would have all of the functionalities contemplated by P.U.C. SUBST. R in the following circumstances: 1) Loads that may cause a safety or health issue if disconnected will not have an advanced meter with disconnect functionality installed. For example, TNMP proposes not to include the disconnection function for traffic lights, metered streetlights, railroad crossings, police stations, hospital facilities, service points providing cathodic protection, and TNMP s emergency facilities. 2) Loads that do not require and will never require a home area network ( HAN ) device will not have an advanced meter with a HAN device installed. For example, TNMP proposes not to include a HAN device for metered streetlights and other applications that would not benefit from a HAN device, such as electric gates, communications power supplies, sprinkler controls, and cathodic protection power supplies. 3) Loads that currently have poly-phase and/or higher than class 200 (200 amp rating) meters will not have a disconnect device until poly-phase advanced meters with a disconnect device are available in the market 4) Loads that have poly-phase and instrument rated meters will not have a HAN device until those advanced meters with HAN devices are available in the market. 1 19

20 TNMP -Advanced Metering System Deployment Plan 5) TNMP not be required to install advanced meters under the circumstances set forth in P.U.C. SUBST. R (g)(6), in advance of the full deployment of advanced meters in a given area. 6) TNMP seeks any and all waivers required from P.U.C. SUBST. R (g)(1)(E)(i) and (G) if and only to the extent those rules require real-time access to data for enduse customers. End-use customers, however, will not have access to data through a web portal unless and until (a) provided by their REP, or (b) the Texas common data repository (hereinafter, Common Repository) and Texas common web portal (hereinafter, Common Portal) are in place pursuant to the Implementation Project Relating to Advanced Metering, Project No Once the Common Portal is completed, customers (in addition to REPs and authorized third parties) will have secure access to data through the Common Portal. 5) Table of Functionality. The following table describes how the Companies AMS meets each of the minimum system features set forth in P.U.C. SUBST. R (g)(1): Rule Requirement TNMP Implementation (A) Automated or remote meter reading; TNMP s AMS technology meets this standard. TNMP will gather 15 minute interval data each day from AMS meters. TNMP will provide a register reading time stamped at 23:59:59 (hh:mm:ss) for each meter. All collected reading data will be made available no later than day after. TNMP meter data gathering process will include a scheduled demand reset of polyphase meters. (B) Two-way communications; TNMP will provide two-way communications between the Common Portal and AMS meter. TNMP will support REP and consumer ability to directly "ping" or "poll" meters as defined by the PUCT AMIT workshops, Project No Please see Section (E), below. TNMP AMS meters will support two-way communications between the AMS meter and ZigBee Smart Energy 1.0 HAN devices that have been certified by the ZigBee Alliance as a ZigBee Compliant Platform and have been certified in the TX Market. Constraints: TNMP' AMS does not support at this time, unsolicited messages from HAN devices that are not 2 20

21 TNMP -Advanced Metering System Deployment Plan (C) (D) (E) Remote disconnection and reconnection for meters rated at or below 200 amps; The capability to time-stamp meter data sent to the independent organization or regional transmission organization ( RTO ) for purposes of wholesale settlement, consistent with time tolerance standards adopted by the independent organization or RTO; The capability to provide direct, real-time access to customer usage data to the customers and the customer s REP, provided that: i. Hourly data shall be transmitted to the electric utility s web portal on a day-after basis. ii. The Commission Staff using a stakeholder process, as soon as practical shall determine, subject to Commission approval, when and how 15-minute interval recorder data shall be made available on the electric utility s web portal; covered by the ZigBee Alliance SmartEnergy protocols, such as, low battery or other device operating status messages. SmartEnergy profile messages from a provisioned HAN device, such as customer load event opt-out notices, are supported. TNMP seeks any and all waivers required from P.U.C. SUBST. R (g)(1)(E)(i) and (G) if and only to the extent those rules require real-time access to data for end-use customers. End-use customers, however, will not have access to data through a web portal unless and until (a) provided by their REP, or (b) the Common Repository and Common Portal are in place pursuant to the Implementation Project Relating to Advanced Metering, Project No Once the Common Portal is completed, customers (in addition to REPs and authorized third parties) will have secure access to data through the Common Portal. TNMP s AMS technology meets this standard. TNMP will deploy advanced meters rated at 200 amps or less that contain a service switch capable of remotely connecting or disconnecting service via the AMS network. TNMP s AMS technology meets this standard. TNMP s proposed AMS has the capability to timestamp meter data. Periodic meter reading data is consistent with the American National Standards Institute (ANSI) C12.19 file table standards accepted by ERCOT, and can be time (hour, minute, and second) and date stamped. TNMP s AMS technology meets this standard. TNMP AMS System will be able to support 15 - minute settlement at ERCOT provided (a) the settlement requirements do not exceed those developed in Project No and (b) settlement at ERCOT, prior to the deployment of the Common Repository, follows the interim market schedule for settlement agreed to by the ERCOT Market Advanced Readings and Settlements Task. Until the Common Repository and Common Portal are available, TNMP will make meter usage interval data and midnight meter register reads available to REPs via a TNMP or third party -hosted secure site. 3 21

22 TNMP -Advanced Metering System Deployment Plan Constraints: End-use customers will not have access to data through a web portal unless and until (a) provided by their REP, or (b) the Common Repository and Common Portal are in place pursuant to Project No Functionality beyond what is contained in the AMIT requirements and future direction such as real time switching or move-ins is out of scope. (F) Means by which the REP can provide price signals to the customer; Explicitly excluded functionality: Move in Request Non-Midnight move-ins Two move-ins in the same 24-hour period Real-time move in Customer selected time of move-in Switch Request Non-Midnight switch Multiple switches in the same 24-hour period Real-time switching Accelerated first available switch date Customer selected time of switch Disconnect For Non-Pay Time-specific disconnect Real-time disconnect Real-time reconnect after DNP Time-specific reconnect Cancels I Date Changes Time-specific time changes Real-time cancels Move out Time-specific move out TNMP s AMS technology meets this standard. TNMP will enable REP price signals over the AMS communications network to ZigBee Smart Energy 1.0 in-home HAN devices. TNMP is currently testing the provisioning capabilities. 4 22

23 TNMP -Advanced Metering System Deployment Plan (G) The capability to provide 15-minute or shorter interval data to REPs, customers, and the independent organization or RTO, on a daily basis, consistent with data availability, transfer and security standards adopted by the independent organization or RTO; TNMP s AMS technology meets this standard. TNMP is working with other Transmission and Distribution Service Providers (TDSPs) to implement an envisioned Common Repository and Common Portal pursuant to the Implementation Project Relating to Advanced Metering, Project No The project is currently in the planning phase. As part of this planning phase, TNMP is analyzing its existing systems and is identifying necessary upgrades to its infrastructure that will be needed as part of the implementation of the Common Portal. Starting no later than the first quarter of 2011 and during the interim period until the Common Repository and Common Portal are available; TNMP will provide or support the following. TNMP will provide REPs with available 15-minute VEE meter usage data via a TNMP-hosted secure site on a daily (no later than day-after) basis. TNMP will provide daily (no later than day-after) available meter register reads via a TNMP-hosted secure site. TNMP will forward such data directly to ERCOT per the Market Advanced Readings and Settlement (MARS) subcommittee guidance and schedule. (H) (I) On-board meter storage of meter data that complies with nationally recognized non-proprietary standards such as in American National Standards Institute (ANSI) C12.19; Open standards and protocols that comply with nationally recognized non-proprietary standards such as in ANSI C12.22, including future revisions thereto; Limitation: End-use customers will not have access to unless and until (a) provided by their REP, or (b) the Common Repository and Common Portal are in place pursuant to Project No TNMP s AMS technology meets this standard. The on-board meter storage feature of the TNMP advanced meter is already C12.19 compliant. TNMP s AMS technology meets this standard. The on-board communication card will be C12.22 compliant. The meter communications card acts as a C12.22 Gateway to the Head-end system which is compliant with ANSI C12 standard. Those meters not C12.22 compliant will be upgraded remotely during TNMP s initial AMS rollout so that all meters will be C12.22 compliant. 5 23

24 TNMP -Advanced Metering System Deployment Plan (J) Capability to communicate with devices inside the premises, including, but not limited to, usage monitoring devices, load control devices, and prepayment systems through a home area network, based on open standards and protocols that comply with nationally recognized non-proprietary standards such as ZigBee, HomePlug or the equivalent; and TNMP s proposed AMS system will support HAN communications with in-home devices using ZigBee SmartEnergy V1.0. TNMP will support the following HAN functionality by 3rd quarter TNMP can support up to 5 provisioned HAN devices per market requirements. TNMP can support REP-to-HAN pre-nodal use projections as proposed in PUCT Project No ) by 3rd quarter 2011 with limitations: o REPs can use group messaging for time-of-use price information updates; o Constraints: ESP device message receipt acknowledgement messages are gathered and returned to REP during normal data gathering processes. PUCT Project No HAN business and technical requirements are still in development. Several HAN requirements, as listed below, have been proposed that are not covered in TNMP AMS filing. TNMP will incorporate, to the extent the means to provide such functionality are commercially available, and the HAN business and technical requirements as set forth in PUCT Project No In the event the means to resolve such constraints or provide such functionality are not commercially available, TNMP will use reasonable efforts to develop or encourage the development of such means. HAN functionality not covered in TNMP filing include: Signal repeaters or range extenders between AMS meters and provisioned HAN devices will not be supported; Detailed monthly HAN communication and operational activity reporting will not be supported; Extensive real time two-way communication sessions between REPs and provisioned HAN devices, including unsolicited messaging initiated by HAN devices to the REP can be supported but at additional cost to the REP for bandwidth 6 24

25 TNMP -Advanced Metering System Deployment Plan consumption over the allotted amount; AMS bandwidth monitoring sufficient to report in near real time bandwidth availability throughout the AMS communications network is not supported; HAN message queue monitoring and status reporting for REPs will be available Q4/2011; TNMP support for near real time messaging to REPs from provisioned HAN devices is supported at additional cost to the REP for bandwidth consumption over the allotted amount; and TNMP s ability to move HAN provisioning information from one meter to another meter when replacing meters is not supported. TNMP s AMS per this filing is limited in how it can support two-way communications between REPs and HAN devices. TNMP will support two way REP-to-HAN communications as follows: HAN device provisioning confirmation messages by Q4/2011 Notification when customer "opts out" of a load control event initiated by a REP by Q4/2011 Notification a meter fails to deliver a REP message to a provisioned HAN device by Q1/2012 (K) The ability to upgrade these minimum capabilities as technology advances and, in the electric utility s determination, become economically feasible. TNMP s AMS technology meets this standard. TNMP meters and communications modules can be remotely upgraded with firmware or configuration changes. This requirement has been tested during TNMP s meter trials. 7 25

26 TEXAS-NEW MEXICO POWER COMPANY TARIFF FOR RETAIL DELIVERY SERVICE ATTACHMENT C 6.1. Rate Schedules Applicable: Entire Certified Service Area Effective Date: November 1, 2010 Page No.: 129 Original RIDER AMCRF ADVANCED METERING COST RECOVERY FACTOR APPLICATION Applicable, pursuant to PURA (h) and Substantive Rule , to Retail Customers receiving metered service for which the Company will install and Advanced Metering System ( AMS ) at any time during the AMS cost recovery period approved by the Public Utility Commission of Texas. Rider AMCRF is not applicable to Retail Customers whose: (1) load is required to be metered by an interval data recorder meter by the independent System Operator (ERCOT), (2) load was metered by and interval data recorder meter prior to the effective date of PUCT Substantive Rule (May 30, 2007), or (3) load is unmetered. NET MONTHLY BILL AMOUNT The AMCRF for each of the Company s applicable retail rate schedules is as follows: Year 1-5 Year 6-12 Rate Schedule Surcharge Surcharge Residential Service $ 4.80 $ 4.17 Per ESI ID per month Secondary Service Less than or Equal to 5 kw $ 5.00 $ 5.00 Per ESI ID per month Secondary Service Greater than 5kW $ $ - Per ESI ID per month Primary Service $ $ - Per ESI ID per month Lighting Service (Metered Facilities) $ $ - Per ESI ID per month NOTICE This rate schedule is subject to the Company s Tariff and Applicable Legal Authorities. 26

27 Attachment D To the Addressed Retail Electric Provider: On, 2010, TEXAS-NEW MEXICO POWER COMPANY (TNMP) filed with the Public Utility Commission of Texas (Commission) a Request for Approval of Advanced Meter System (AMS) Deployment Plan and Request for AMS Surcharges. TNMP requests the Commission to approve their AMS deployment plan pursuant to P.U.C. SUBST. R and to approve, pursuant to P.U.C. SUBST. R (k), the AMS surcharges for recovery of the reasonable and necessary costs which TNMP will incur under said deployment plan. If approved, TNMP s surcharges will go into effect with the November 2010 billing month (which commences on November 1, 2010). The AMS surcharges will apply to electric service to residential customers and non-residential customers, other than those who have interval demand recording (IDR) meters or take unmetered service. The AMS surcharge will be billed to the retail electric providers (REPs) providing retail electric service to such customers in TNMP s service areas. The costs recovered through the AMS surcharges will be reviewed by the Commission in a reconciliation proceeding to be held in the future on a schedule to be determined by the Commission. A copy of TNMP s filing is available for inspection at its offices at 225 E. John Carpenter Freeway, Suite 1500, Irving, Texas 75062, telephone (469) Persons who wish to intervene in or comment upon the filing should notify the Public Utility Commission of Texas as soon as possible, as an intervention deadline of, 2010, has been imposed. A request to intervene or further information should be mailed to the Public Utility Commission of Texas, Post Office Box 13326, Austin, Texas , and reference Docket No.. Further information may also be obtained by calling the Public Utility Commission of Texas at (512) or (888) (toll free). Hearing- and speech-impaired individuals with text telephones (TTY) may contact the Commission at (512) Very truly yours, Kendall A. Evans Regulatory Policy and Planning 27

28 Attachment E NOTICE OF REQUEST FOR APPROVAL FILED WITH THE PUBLIC UTILITY COMMISSION OF TEXAS On, 2010, TEXAS-NEW MEXICO POWER COMPANY (TNMP), a regulated electric transmission and distribution utility, filed with the Public Utility Commission of Texas (Commission) a Request for Approval of Advanced Meter System (AMS) Deployment Plan and Request for AMS Surcharges. The requested AMS surcharge is designed to recover the reasonable and necessary costs that TNMP will incur under the AMS deployment plan If approved, the requested AMS surcharge will go into effect with the November 2010 billing month (which commences on November 1, 2010). The AMS surcharge will apply to electric service to residential and non-residential customers in TNMP's service area, other than those who have interval demand recording (IDR) meters or take unmetered service. The AMS surcharge will be billed to the retail electric providers (REPs) who provide retail electric service to these customers. The amount of AMS surcharge borne by an individual end-use retail customer will depend on whether its REP passes the approved AMS surcharge along to the enduse customer. The costs recovered through the AMS surcharge will be reviewed by the Commission in a reconciliation proceeding to be held in the future on a schedule to be determined by the Commission. A copy of TNMP's filing is available for inspection at TNMP's offices at 225 E. John Carpenter Freeway, Suite 1500, Irving, Texas 75062, telephone (469) Persons who wish to intervene in or comment upon the filing should notify the Public Utility Commission of Texas as soon as possible, as an intervention deadline of, 2010, has been imposed. A request to intervene or further information should be mailed to the Public Utility Commission of Texas, Post Office Box 13326, Austin, Texas , and reference Docket No.. Further information may also be obtained by calling the Public Utility Commission of Texas at (512) or (888) (toll free). Hearing- and speechimpaired individuals with text telephones (TTY) may contact the Commission at (512)

29 Protective Order ATTACHMENT F Attachment to Order No. DRAFT DOCKET NO. TEXAS-NEW MEXICO POWER COMPANY'S REQUEST FOR APPROVAL OF ADVANCED METER SYSTEM (AMS) DEPLOYMENT PLAN AND REQUEST FOR AMS SURCHARGES PUBLIC UTILITY COMMISSION OF TEXAS PROTECTIVE ORDER This Protective Order shall govern the use of all information deemed confidential (Protected Materials) or highly confidential (Highly Sensitive Protected Materials) by a party providing information to the Public Utility Commission of Texas (Commission), including information whose confidentiality is currently under dispute. It is ORDERED that: 1. Designation of Protected Materials. Upon producing or filing a document, including, but not limited to, records stored or encoded on a computer disk or other similar electronic storage medium in this proceeding, the producing party may designate that document, or any portion of it, as confidential pursuant to this Protective Order by typing or stamping on its face PROTECTED PURSUANT TO PROTECTIVE ORDER ISSUED IN DOCKET NO. or words to this effect and consecutively Bates Stamping each page. Protected Materials and Highly Sensitive Protected Materials include not only the documents so designated, but also the substance of the information contained in the documents and any description, report, summary, or statement about the substance of the information contained in the documents. 2. Materials Excluded from Protected Materials Designation. Protected Materials shall not include any information or document contained in the public files of the Commission or any other federal or state agency, court, or local governmental authority subject to the Texas Public Information Act. Protected Materials also shall not include documents or information which at the time of, or prior to disclosure in a proceeding, is or was public knowledge, or Page 1 of 18 29

30 Protective Order ATTACHMENT F Attachment to Order No. DRAFT which becomes public knowledge other than through disclosure in violation of this Protective Order. 3. Reviewing Party. For the purposes of this Protective Order, a Reviewing Party is any party to this docket. 4. Procedures for Designation of Protected Materials. On or before the date the Protected Materials or Highly Sensitive Protected Materials are provided to the Commission, the producing party shall file with the Commission and deliver to each party to the proceeding a written statement, which may be in the form of an objection, indicating: (1) any and all exemptions to the Public Information Act, TEX. GOV T CODE ANN., Chapter 552, claimed to be applicable to the alleged Protected Materials; (2) the reasons supporting the providing party s claim that the responsive information is exempt from public disclosure under the Public Information Act and subject to treatment as protected materials; and (3) that counsel for the providing party has reviewed the information sufficiently to state in good faith that the information is exempt from public disclosure under the Public Information Act and merits the Protected Materials designation. 5. Persons Permitted Access to Protected Materials. Except as otherwise provided in this Protective Order, a Reviewing Party shall be permitted access to Protected Materials only through its Reviewing Representatives who have signed the Protective Order Certification Form. Reviewing Representatives of a Reviewing Party include its counsel of record in this proceeding and associated attorneys, paralegals, economists, statisticians, accountants, consultants, or other persons employed or retained by the Reviewing Party and directly engaged in this proceeding. At the request of the PUC Commissioners, or their staff, copies of Protected Materials may be produced by Commission Staff (Staff) or the Commission's Docket Management and Advising Division (CADM) to the Commissioners. The Commissioners and their staff shall be informed of the existence and coverage of this Protective Order and shall observe the restrictions of the Protective Order. 6. Highly Sensitive Protected Material Described. The term Highly Sensitive Protected Materials is a subset of Protected Materials and refers to documents or information Page 2 of 18 30

31 Protective Order ATTACHMENT F Attachment to Order No. DRAFT which a producing party claims is of such a highly sensitive nature that making copies of such documents or information or providing access to such documents to employees of the Reviewing Party (except as set forth herein) would expose a producing party to unreasonable risk of harm, including but not limited to: (1) customer-specific information protected by (c) of the Public Utility Regulatory Act 1 ; (2) contractual information pertaining to contracts that specify that their terms are confidential or which are confidential pursuant to an order entered in litigation to which the producing party is a party; (3) market-sensitive fuel price forecasts, wholesale transactions information and/or market-sensitive marketing plans; and (4) business operations or financial information that is commercially sensitive. Documents or information so classified by a producing party shall bear the designation HIGHLY SENSITIVE PROTECTED MATERIALS PROVIDED PURSUANT TO PROTECTIVE ORDER ISSUED IN DOCKET NO. or words to this effect and shall be consecutively Bates Stamped in accordance with the provisions of this Protective Order. The provisions of this Protective Order pertaining to Protected Materials also apply to Highly Sensitive Protected Materials, except where this Protective Order provides for additional protections for Highly Sensitive Protected Materials. In particular, the procedures herein for challenging the producing party s designation of information as Protected Materials also apply to information that a producing party designates as Highly Sensitive Protected Materials. 7. Restrictions on Copying and Inspection of Highly Sensitive Protected Material. Except as expressly provided herein, only one copy may be made of any Highly Sensitive Protected Materials except that additional copies may be made in order to have sufficient copies for introduction of the material into the evidentiary record if the material is to be offered for admission into the record. A record of any copies that are made of Highly Sensitive Protected Material shall be kept and a copy of the record shall be sent to the producing party at the time the copy or copies are made. The record shall include information on the location and the person in possession of the copy. Highly Sensitive Protected Material shall be made available for inspection only at the location or locations provided by the producing party, except as provided by Paragraphs 9 and 13. Limited notes may be made of Highly Sensitive 1 Public Utility Regulatory Act, TEX. UTIL. CODE ANN., (c) (Vernon 2007 & Supp. 2008) (PURA). Page 3 of 18 31

32 Protective Order ATTACHMENT F Attachment to Order No. DRAFT Protected Materials, and such notes shall themselves be treated as Highly Sensitive Protected Materials unless such notes are limited to a description of the document and a general characterization of its subject matter in a manner that does not state any substantive information contained in the document. 8. Restricting Persons Who May Have Access to Highly Sensitive Protected Material. With the exception of Commission Staff, The Office of the Attorney General (OAG), and the Office of Public Utility Counsel (OPC), and except as provided herein, the Reviewing Representatives for the purpose of access to Highly Sensitive Protected Materials may be persons who are: (1) outside counsel for the Reviewing Party, (2) outside consultants for the Reviewing Party working under the direction of Reviewing Party s counsel or, (3) employees of the Reviewing Party working with and under the direction of Reviewing Party s counsel who have been authorized by the presiding officer to review Highly Sensitive Protected Materials. The Reviewing Party shall limit the number of Reviewing Representatives that review each Highly Sensitive Protected document to the minimum number of persons necessary. The Reviewing Party is under a good faith obligation to limit access to each portion of any Highly Sensitive Protected Materials to two Reviewing Representatives whenever possible. Reviewing Representatives for Commission Staff, the OAG, and OPC, for the purpose of access to Highly Sensitive Protected Materials, shall consist of their respective counsel of record in this proceeding and associated attorneys, paralegals, economists, statisticians, accountants, consultants, or other persons employed or retained by them and directly engaged in these proceedings. 9. Copies Provided of Highly Sensitive Protected Material. A producing party shall provide one copy of Highly Sensitive Protected Materials specifically requested by the Reviewing Party to the person designated by the Reviewing Party who must be a person authorized to review Highly Sensitive Protected Material under Paragraph 8, and be either outside counsel or an outside consultant. Other representatives of the reviewing party who are authorized to view Highly Sensitive Material may review the copy of Highly Sensitive Protected Materials at the office of the Reviewing Party s representative designated to receive the information. Each reviewing party may make two additional copies of Highly Sensitive Page 4 of 18 32

33 Protective Order ATTACHMENT F Attachment to Order No. DRAFT documents for outside consultants whose business offices are located outside of Travis County. The additional copies may be maintained at the outside consultants offices outside of Travis County. All restrictions on Highly Sensitive documents in this Order shall apply to the additional copies maintained in the outside consultants offices. Any Highly Sensitive Protected documents provided to a Reviewing Party may not be copied except as provided in Paragraph 7 and shall be returned along with any copies made pursuant to Paragraph 7 to the producing party within two weeks after the close of the evidence in this proceeding. The restrictions contained herein do not apply to Commission Staff, OPC, and the OAG when the OAG is a representing a party to the proceeding. 10. Procedures in Paragraphs Apply to Commission Staff, OPC, and the OAG and Control in the Event of Conflict. The procedures set forth in Paragraphs 10 through 14 apply to responses to requests for documents or information that the producing party designates as Highly Sensitive Protected Materials and provides to Commission Staff, OPC, and the OAG in recognition of their purely public functions. To the extent the requirements of Paragraphs 10 through 14 conflicts with any requirements contained in other paragraphs of this Protective Order, the requirements of these Paragraphs shall control. 11. Copy of Highly Sensitive Protected Material to be Provided to Commission Staff, OPC and the OAG. When, in response to a request for information by a Reviewing Party, the producing party makes available for review documents or information claimed to be Highly Sensitive Protected Materials, the producing party shall also deliver one copy of the Highly Sensitive Protected Materials to the Commission Staff, OPC (if OPC is a party), and the OAG (if the OAG is representing a party) in Austin, Texas. Provided however, that in the event such Highly Sensitive Protected Materials are voluminous, the materials will be made available for review by Commission Staff, OPC (if OPC is a party), and the OAG (if the OAG is representing a party) at the designated office in Austin, Texas. The Commission Staff, OPC (if OPC is a party), and the OAG (if the OAG is representing a party) may request such copies as are necessary of such voluminous material under the copying procedures set forth herein. 12. Delivery of the Copy of Highly Sensitive Protected Material to Staff and Outside Consultants. The Commission Staff, OPC (if OPC is a party), and the OAG (if the OAG is Page 5 of 18 33

34 Protective Order ATTACHMENT F Attachment to Order No. DRAFT representing a party) may deliver the copy of Highly Sensitive Protected Materials received by them to the appropriate members of their staff for review, provided such staff members first sign the certification provided in Paragraph 15. After obtaining the agreement of the producing party, Commission Staff, OPC (if OPC is a party), and the OAG (if the OAG is representing a party) may deliver the copy of Highly Sensitive Protected Materials received by it to the agreed, appropriate members of their outside consultants for review, provided such outside consultants first sign the certification attached hereto. 13. Restriction on Copying by Commission Staff, OPC and the OAG. Except as allowed by Paragraph 7 or by this Paragraph 13, Commission Staff, OPC and the OAG may not make additional copies of the Highly Sensitive Protected Materials furnished to them unless the producing party agrees in writing otherwise, or, upon a showing of good cause, the presiding officer directs otherwise. Limited notes may be made by Commission Staff, OPC (if OPC is a party), and the OAG (if the OAG is representing a party) of Highly Sensitive Protected Materials furnished to them and all such handwritten notes will be treated as Highly Sensitive Protected Materials as are the materials from which the notes are taken. Commission Staff, OPC (if OPC is a party), and the OAG (if OAG is a party) may make two additional copies of Highly Sensitive documents for outside consultants whose business offices are located outside of Travis County. The additional copies may be maintained at the outside consultants offices outside of Travis County. All restrictions on Highly Sensitive documents in this Order shall apply to the additional copies maintained in the outside consultants offices. 14. Public Information Requests. In the event of a request for any of the Highly Sensitive Protected Materials under the Public Information Act, an authorized representative of the Commission OPC, or the OAG may furnish a copy of the requested Highly Sensitive Protected Materials to the Open Records Division at the OAG together with a copy of this Protective Order after notifying the producing party that such documents are being furnished to the OAG. Such notification may be provided simultaneously with the delivery of the Highly Sensitive Protected Materials to the OAG. Page 6 of 18 34

35 Protective Order ATTACHMENT F Attachment to Order No. DRAFT 15. Required Certification. Each person who inspects the Protected Materials shall, before such inspection, agree in writing to the following certification set forth in the Attachment to this Protective Order: I certify my understanding that the Protected Materials are provided to me pursuant to the terms and restrictions of the Protective Order in this docket, and that I have been given a copy of it and have read the Protective Order and agree to be bound by it. I understand that the contents of the Protected Materials, any notes, memoranda, or any other form of information regarding or derived from the Protected Materials shall not be disclosed to anyone other than in accordance with the Protective Order and unless I am an employee of the Commission or OPC shall be used only for the purpose of the proceeding in Docket No.. I acknowledge that the obligations imposed by this certification are pursuant to such Protective Order. Provided, however, if the information contained in the Protected Materials is obtained from independent public sources, the understanding stated herein shall not apply. In addition, Reviewing Representatives who are permitted access to Highly Sensitive Protected Material under the terms of this Protective Order shall, before inspection of such material, agree in writing to the following certification set forth in the Attachment to this Protective Order: I certify that I am eligible to have access to Highly Sensitive Protected Material under the terms of the Protective Order in this docket. A copy of each signed certification shall be provided by the reviewing party to Counsel for the producing party and served upon all parties of record. 16. Disclosures Between Reviewing Representatives and Continuation of Disclosure Restrictions After a Person is no Longer Engaged in the Proceeding. Any Reviewing Representative may disclose Protected Materials, other than Highly Sensitive Protected Materials, to any other person who is a Reviewing Representative provided that, if the person to whom disclosure is to be made has not executed and provided for delivery of a signed certification to the party asserting confidentiality, that certification shall be executed prior to any disclosure. A Reviewing Representative may disclose Highly Sensitive Protected Material Page 7 of 18 35

36 Protective Order ATTACHMENT F Attachment to Order No. DRAFT to other Reviewing Representatives who are permitted access to such material and have executed the additional certification required for persons who receive access to Highly Sensitive Protected Material. In the event that any Reviewing Representative to whom Protected Materials are disclosed ceases to be engaged in these proceedings, access to Protected Materials by that person shall be terminated and all notes, memoranda, or other information derived from the protected material shall either be destroyed or given to another Reviewing Representative of that party who is authorized pursuant to this Protective Order to receive the protected materials. Any person who has agreed to the foregoing certification shall continue to be bound by the provisions of this Protective Order so long as it is in effect, even if no longer engaged in these proceedings. 17. Producing Party to Provide One Copy of Certain Protected Material and Procedures for Making Additional Copies of Such Materials. Except for Highly Sensitive Protected Materials, which shall be provided to the Reviewing Parties pursuant to Paragraphs 9, and voluminous Protected Materials, the producing party shall provide a Reviewing Party one copy of the Protected Materials upon receipt of the signed certification described in Paragraph 15. Except for Highly Sensitive Protected Materials, a Reviewing Party may make further copies of Protected Materials for use in this proceeding pursuant to this Protective Order, but a record shall be maintained as to the documents reproduced and the number of copies made, and upon request the Reviewing Party shall provide the party asserting confidentiality with a copy of that record. 18. Procedures Regarding Voluminous Protected Materials. Production of voluminous Protected Materials will be governed by P.U.C. PROC. R (h). Voluminous Protected Materials will be made available in the producing party s voluminous room, in Austin, Texas, or at a mutually agreed upon location, Monday through Friday, 9:00 a.m. to 5:00 p.m. (except on state or Federal holidays), and at other mutually convenient times upon reasonable request. 19. Reviewing Period Defined. The Protected Materials may be reviewed only during the Reviewing Period, which shall commence upon entry of this Protective Order and continue until the expiration of the Commission s plenary jurisdiction. The Reviewing Period shall reopen if the Commission regains jurisdiction due to a remand as provided by law. Protected Page 8 of 18 36

37 Protective Order ATTACHMENT F Attachment to Order No. DRAFT materials that are admitted into the evidentiary record or accompanying the evidentiary record as offers of proof may be reviewed throughout the pendency of this proceeding and any appeals. 20. Procedures for Making Copies of Voluminous Protected Materials. Other than Highly Sensitive Protected Materials, Reviewing Parties may take notes regarding the information contained in voluminous Protected Materials made available for inspection or they may make photographic, mechanical or electronic copies of the Protected Materials, subject to the conditions hereof; provided, however, that before photographic, mechanical or electronic copies can be made, the Reviewing Party seeking photographic, mechanical or electronic copies must complete a written receipt for copies on the attached form identifying each piece of Protected Materials or portions thereof the Reviewing Party will need. 21. Protected Materials to be Used Solely for the Purposes of These Proceedings. All Protected Materials shall be made available to the Reviewing Parties and their Reviewing Representatives solely for the purposes of these proceedings. Access to the Protected Materials may not be used in the furtherance of any other purpose, including, without limitation: (1) any other pending or potential proceeding involving any claim, complaint, or other grievance of whatever nature, except appellate review proceedings that may arise from or be subject to these proceedings; or (2) any business or competitive endeavor of whatever nature. Because of their statutory regulatory obligations, these restrictions do not apply to Commission Staff or OPC. 22. Procedures for Confidential Treatment of Protected Materials and Information Derived from those Materials. Protected Materials, as well as a Reviewing Party s notes, memoranda, or other information regarding or derived from the Protected Materials are to be treated confidentially by the Reviewing Party and shall not be disclosed or used by the Reviewing Party except as permitted and provided in this Protective Order. Information derived from or describing the Protected Materials shall be maintained in a secure place and shall not be placed in the public or general files of the Reviewing Party except in accordance with the provisions of this Protective Order. A Reviewing Party must take all reasonable precautions to insure that the Protected Materials including notes and analyses made from Page 9 of 18 37

38 Protective Order ATTACHMENT F Attachment to Order No. DRAFT Protected Materials that disclose Protected Materials are not viewed or taken by any person other than a Reviewing Representative of a Reviewing Party. 23. Procedures for Submission of Protected Materials. If a Reviewing Party tenders for filing any Protected Materials, including Highly Sensitive Protected Materials, or any written testimony, exhibit, brief, motion or other type of pleading or other submission at the Commission or before any other judicial body that quotes from Protected Materials or discloses the content of Protected Materials, the confidential portion of such submission shall be filed and served in sealed envelopes or other appropriate containers endorsed to the effect that they contain Protected Material or Highly Sensitive Protected Material and are sealed pursuant to this Protective Order. If filed at the Commission, such documents shall be marked PROTECTED MATERIAL and shall be filed under seal with the presiding officer and served under seal to the counsel of record for the Reviewing Parties. The presiding officer may subsequently, on his/her own motion or on motion of a party, issue a ruling respecting whether or not the inclusion, incorporation or reference to Protected Materials is such that such submission should remain under seal. If filing before a judicial body, the filing party: (1) shall notify the party which provided the information within sufficient time so that the providing party may seek a temporary sealing order; and (2) shall otherwise follow the procedures set forth in Rule 76a, Texas Rules of Civil Procedure. 24. Maintenance of Protected Status of Materials During Pendency of Appeal of Order Holding Materials are not Protected Materials. In the event that the presiding officer at any time in the course of this proceeding finds that all or part of the Protected Materials are not confidential or proprietary, by finding, for example, that such materials have entered the public domain or materials claimed to be Highly Sensitive Protected Materials are only Protected Materials, those materials shall nevertheless be subject to the protection afforded by this Protective Order for three (3) full working days, unless otherwise ordered, from the date the party asserting confidentiality receives notice of the presiding officer s order. Such notification will be by written communication. This provision establishes a deadline for appeal of a presiding officer s order to the Commission. In the event an appeal to the Commissioners is filed within those three (3) working days from notice, the Protected Page 10 of 18 38

39 Protective Order ATTACHMENT F Attachment to Order No. DRAFT Materials shall be afforded the confidential treatment and status provided in this Protective Order during the pendency of such appeal. Neither the party asserting confidentiality nor any Reviewing Party waives its right to seek additional administrative or judicial remedies after the Commission s denial of any appeal. 25. Notice of Intent to Use Protected Materials or Change Materials Designation. Parties intending to use Protected Materials shall notify the other parties prior to offering them into evidence or otherwise disclosing such information into the record of the proceeding. During the pendency of Docket No. at the Commission, in the event that a Reviewing Party wishes to disclose Protected Materials to any person to whom disclosure is not authorized by this Protective Order, or wishes to have changed the designation of certain information or material as Protected Materials by alleging, for example, that such information or material has entered the public domain, such Reviewing Party shall first file and serve on all parties written notice of such proposed disclosure or request for change in designation, identifying with particularity each of such Protected Materials. A Reviewing Party shall at any time be able to file a written motion to challenge the designation of information as Protected Materials. 26. Procedures to Contest Disclosure or Change in Designation. In the event that the party asserting confidentiality wishes to contest a proposed disclosure or request for change in designation, the party asserting confidentiality shall file with the appropriate presiding officer its objection to a proposal, with supporting affidavits, if any, within five (5) working days after receiving such notice of proposed disclosure or change in designation. Failure of the party asserting confidentiality to file such an objection within this period shall be deemed a waiver of objection to the proposed disclosure or request for change in designation. Within five (5) working days after the party asserting confidentiality files its objection and supporting materials, the party challenging confidentiality may respond. Any such response shall include a statement by counsel for the party challenging such confidentiality that he or she has reviewed all portions of the materials in dispute and without disclosing the Protected Materials, a statement as to why the Protected Materials should not be held to be confidential under current legal standards, or alternatively that the party asserting confidentiality for some reason Page 11 of 18 39

40 Protective Order ATTACHMENT F Attachment to Order No. DRAFT did not allow such counsel to review such materials. If either party wishes to submit the material in question for in camera inspection, it shall do so no later than five (5) working days after the party challenging confidentiality has made its written filing. 27. Procedures for Presiding Officer Determination Regarding Proposed Disclosure or Change in Designation. If the party asserting confidentiality files an objection, the appropriate presiding officer will determine whether the proposed disclosure or change in designation is appropriate. Upon the request of either the producing or reviewing party or upon the presiding officer s own initiative, the presiding officer may conduct a prehearing conference. The burden is on the party asserting confidentiality to show that such proposed disclosure or change in designation should not be made. If the presiding officer determines that such proposed disclosure or change in designation should be made, disclosure shall not take place earlier than three (3) full working days after such determination unless otherwise ordered. No party waives any right to seek additional administrative or judicial remedies concerning such presiding officer s ruling. 28. Maintenance of Protected Status During Periods Specified for Challenging Various Orders. Any party electing to challenge, in the courts of this state, a Commission or presiding officer determination allowing disclosure or a change in designation shall have a period of ten (10) days from: (1) the date of an unfavorable Commission order; or (2) if the Commission does not rule on an appeal of an interim order, the date an appeal of an interim order to the Commission is overruled by operation of law, to obtain a favorable ruling in state district court. Any party challenging a state district court determination allowing disclosure or a change in designation shall have an additional period of ten (10) days from the date of the order to obtain a favorable ruling from a state appeals court. Finally, any party challenging a determination of a state appeals court allowing disclosure or a change in designation shall have an additional period of ten (10) days from the date of the order to obtain a favorable ruling from the state supreme court, or other appellate court. All Protected Materials shall be afforded the confidential treatment and status provided for in this Protective Order during the periods for challenging the various orders referenced in this Paragraph. For purposes of this Page 12 of 18 40

41 Protective Order ATTACHMENT F Attachment to Order No. DRAFT Paragraph, a favorable ruling of a state district court, state appeals court, Supreme Court or other appellate court includes any order extending the deadlines set forth in this Paragraph. 29. Other Grounds for Objection to Use of Protected Materials Remain Applicable. Nothing in this Protective Order shall be construed as precluding any party from objecting to the use of Protected Materials on grounds other than confidentiality, including the lack of required relevance. Nothing in this Protective Order constitutes a waiver of the right to argue for more disclosure, provided, however, that unless and until such additional disclosure is order by the Commission or a court, all parties will abide by the restrictions imposed by the Protective Order. 30. Protection of Materials from Unauthorized Disclosure. All notices, applications, responses or other correspondence shall be made in a manner which protects Protected Materials from unauthorized disclosure. 31. Return of Copies of Protected Materials and Destruction of Information Derived from Protected Materials. Following the conclusion of these proceedings, each Reviewing Party must, no later than thirty (30) days following receipt of the notice described below, return to the party asserting confidentiality all copies of the Protected Materials provided by that party pursuant to this Protective Order and all copies reproduced by a Reviewing Party, and counsel for each Reviewing Party must provide to the party asserting confidentiality a letter by counsel that, to the best of his or her knowledge, information, and belief, all copies of notes, memoranda, and other documents regarding or derived from the Protected Materials (including copies of Protected Materials) that have not been so returned, if any, have been destroyed, other than notes, memoranda, or other documents which contain information in a form which, if made public, would not cause disclosure of the substance of Protected Materials. As used in this Protective Order, conclusion of these proceedings refers to the exhaustion of available appeals, or the running of the time for the making of such appeals, as provided by applicable law. If, following any appeal, the Commission conducts a remand proceeding, then the conclusion of these proceedings is extended by the remand to the exhaustion of available appeals of the remand, or the running of the time for making such appeals of the remand, as provided by applicable law. Promptly following the conclusion of these proceedings, counsel Page 13 of 18 41

42 Protective Order ATTACHMENT F Attachment to Order No. DRAFT for the party asserting confidentiality will send a written notice to all other parties, reminding them of their obligations under this Paragraph. Nothing in this Paragraph shall prohibit counsel for each Reviewing Party from retaining two (2) copies of any filed testimony, brief, application for rehearing, hearing exhibit or other pleading which refers to Protected Materials provided that any such Protected Materials retained by counsel shall remain subject to the provisions of this Protective Order. 32. Applicability of Other Law. This Protective Order is subject to the requirements of the Public Information Act 2, the Open Meetings Act 3, and any other applicable law, provided that parties subject to those acts will give the party asserting confidentiality notice, if possible under those acts, prior to disclosure pursuant to those acts. 33. Procedures for Release of Information Under Order. If required by order of a governmental or judicial body, the Reviewing Party may release to such body the confidential information required by such order; provided, however, that (1) the Reviewing Party shall notify the party asserting confidentiality of such order at least five (5) calendar days in advance of the release of the information in order for the party asserting confidentiality to contest any release of the confidential information; (2) the Reviewing Party shall notify the producing party that there is a request for such information within five (5) calendar days of the date the Reviewing Party is notified of the request for information; and (3) the Reviewing Party shall use its best efforts to prevent such materials from being disclosed to the public. The terms of this Protective Order do not preclude the Reviewing Party from complying with any valid and enforceable order of a state or federal court with competent jurisdiction specifically requiring disclosure of Protected Materials earlier than contemplated herein. 34. Best Efforts Defined. The term best efforts as used in the preceding paragraph requires that the Reviewing Party attempt to ensure that disclosure is not made unless such disclosure is pursuant to a final order of a Texas governmental or Texas judicial body or written opinion of the Texas Attorney General which was sought in compliance with the Public Information Act. The Reviewing Party is not required to delay compliance with a lawful order 2 TEX. GOV T CODE ANN (Vernon 1994 & Supp. 2008). Page 14 of 18 42

43 Protective Order ATTACHMENT F Attachment to Order No. DRAFT to disclose such information but is simply required to timely notify the party asserting confidentiality, or its counsel, that it has received a challenge to the confidentiality of the information and that the Reviewing Party will either proceed under the provisions of of the Public Information Act, or intends to comply with the final governmental or court order. 35. Notify Defined. Notify for purposes of Paragraphs 33 and 34 shall mean written notice to the party asserting confidentiality at least five (5) calendar days prior to release; including when a Reviewing Party receives a request under the Public Information Act. However, the Commission or OPC may provide a copy of Protected Materials to the Open Records Division of the OAG as provided herein. 36. Requests for Non-Disclosure. If the producing party asserts that the requested information should not be disclosed at all, or should not be disclosed to certain parties under the protection afforded by this Order, the producing party shall tender the information for in camera review to the presiding officer within five (5) calendar days of the request. At the same time, the producing party shall file and serve on all parties its argument, including any supporting affidavits, in support of its position of non-disclosure. The burden is on the producing party to establish that the material should not be disclosed. The producing party shall serve a copy of the information under the classification of Highly Sensitive Protected Material to all parties requesting the information that the producing party has not alleged should be prohibited from reviewing the information. Parties wishing to respond to the producing party s argument for non-disclosure shall do so within three (3) working days. Responding parties should explain why the information should be disclosed to them, including why disclosure is necessary for a fair adjudication of the case if the material is determined to constitute a trade secret. If the Presiding Officer finds that the information should be disclosed as Protected Material under the terms of this Protective Order, the Presiding Officer shall stay the order of disclosure for such period of time as the Presiding Officer deems necessary to allow the producing party to appeal the ruling to the commission. 3 TEX. GOV T CODE ANN (Vernon 1994 & Supp. 2008). Page 15 of 18 43

44 Protective Order ATTACHMENT F Attachment to Order No. DRAFT 37. Sanctions Available for Abuse of Designation. If the Presiding Officer finds that a producing party unreasonably designated material as Protected Material or as Highly Sensitive Protected Material, or unreasonably attempted to prevent disclosure pursuant to Paragraph 36, the Presiding Officer may sanction the producing party pursuant to P.U.C. PROC. R Modification of Protective Order. Each party shall have the right to seek changes in this Protective Order as appropriate from the Presiding Officer. 39. Breach of Protective Order. In the event of a breach of the provisions of this Protective Order, the producing party, if it sustains its burden of proof required to establish the right to injunctive relief, shall be entitled to an injunction against such breach without any requirements to post bond as a condition of such relief. The producing party shall not be relieved of proof of any element required to establish the right to injunctive relief. In addition to injunctive relief, the producing party shall be entitled to pursue any other form of relief to which it is entitled. Page 16 of 18 44

45 Protective Order ATTACHMENT F Attachment to Order No. DRAFT ATTACHMENT A Protective Order Certification I certify my understanding that the Protected Materials are provided to me pursuant to the terms and restrictions of the Protective Order in this docket, and that I have been given a copy of it and have read the Protective Order and agree to be bound by it. I understand that the contents of the Protected Materials, any notes, memoranda, or any other form of information regarding or derived from the Protected Materials shall not be disclosed to anyone other than in accordance with the Protective Order and unless I am an employee of the Commission or OPC shall be used only for the purpose of the proceeding in Docket No.. I acknowledge that the obligations imposed by this certification are pursuant to such Protective Order. Provided, however, if the information contained in the Protected Materials is obtained from independent public sources, the understanding stated herein shall not apply. Signature Party Represented Printed Name Date I certify that I am eligible to have access to Highly Sensitive Protected Material under the terms of the Protective Order in this docket. Signature Party Represented Printed Name Date Page 17 of 18 45

46 Protective Order ATTACHMENT F Attachment to Order No. DRAFT ATTACHMENT B I request to view/copy the following documents: Document Requested # of Copies Non-Confidential Confidential &/or HS Signature Party Represented Printed Name Date Page 18 of 18 46

47 PUC DOCKET NO. BEFORE THE PUBLIC UTILITY COMMISSION OF TEXAS TEXAS-NEW MEXICO POWER COMPANY REQUEST FOR APPROVAL OF AN ADVANCE METERING SYSTEM (AMS) DEPLOYMENT AND AMS SURCHARGE PREPARED DIRECT TESTIMONY AND EXHIBITS OF STACY R. WHITEHURST ON BEHALF OF TEXAS-NEW MEXICO POWER COMPANY 47

48 DIRECT TESTIMONY OF STACY R. WHITEHURST PUC DOCKET NO. TABLE OF CONTENTS I. INTRODUCTION AND QUALIFICATIONS... 1 II. PURPOSE OF TESTIMONY... 1 III. OVERVIEW OF TNMP S APPLICATION... 2 IV. OVERVIEW OF TNMP S AMS DEPLOYMENT PLAN... 4 V. COMPLIANCE WITH THE COMMISSION S ADVANCE METER RULE... 8 VI. WAIVERS VII. TNMP S CUSTOMER EDUCATION PLAN VIII. TNMP MCKINSEY MODEL ASSUMPTIONS IX. ADDITIONAL REQUESTS X. CONCLUSION EXHIBIT SRW-1 EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE EXHIBIT SRW-2 CONFIDENTIAL CUSTOMER EDUCATION CAMPAIGN PROPOSAL EXHIBIT SRW-3 RIDER AMCRF (ADVANCE METERING COST RECOVERY FACTOR) EXHIBIT SRW-4 MOODY S REVISED OUTLOOK FOR TNMP i 48

49 DIRECT TESTIMONY OF STACY R. WHITEHURST PUC DOCKET NO I. INTRODUCTION AND QUALIFICATIONS Q. PLEASE STATE YOUR NAME, BUSINESS ADDRESS, AND PLACE OF EMPLOYMENT. A. My name is Stacy R. Whitehurst. I serve as Supervisor of Regulatory Policy and Planning for TNMP in the Regulatory Policy Department at PNMR Services Company ( PNMR Services ), a wholly owned subsidiary of PNM Resources, Inc. ( PNM Resources ). My business address is 225 E. John Carpenter Freeway, Suite 1500 Irving, Texas Q. ON WHOSE BEHALF ARE YOU TESTIFYING? A. I am testifying on behalf of Texas-New Mexico Power Company ( TNMP or Company ). Q. PLEASE DESCRIBE YOUR EDUCATIONAL BACKGROUND AND PROFESSIONAL EXPERIENCE. A. Exhibit SRW-1 describes my background and experience, including proceedings in which I have provided testimony. Q. PLEASE DESCRIBE YOUR DUTIES AS THE SUPERVISOR OF REGULATORY POLICY AND PLANNING FOR PNMR SERVICES. A. As the Supervisor of Regulatory Policy and Planning, I report directly to the Vice President of Regulatory Affairs. I am in charge of all regulatory activities for TNMP, which include compliance filings, complaints, rulemakings and contested cases. Q. HAVE YOU PREPARED ANY EXHIBITS? A. Yes. I am sponsoring Exhibits SRW-1 through Exhibits SRW-4, which are attached to my testimony. Each of these exhibits was prepared by me or under my direction and control. The information contained in these exhibits is true and correct to the best of my knowledge and belief. 25 II. PURPOSE OF TESTIMONY Q. WHAT IS THE PURPOSE OF YOUR TESTIMONY IN THIS PROCEEDING? A. The purpose of my testimony is the following: 1 49

50 DIRECT TESTIMONY OF STACY R. WHITEHURST PUC DOCKET NO provide an overview of the filing made by TNMP pursuant to P.U.C. SUBST. R and to introduce TNMP s witnesses and the subject matters of their testimonies; describe the objectives sought through the installation of an AMS system; provide an overview of the AMS technology being deployed at TNMP; and provide an explanation of certain McKinsey Model Assumptions. 7 III. OVERVIEW OF TNMP S APPLICATION Q. WHY IS TNMP MAKING THIS FILING? A. Through this petition and application, in accordance with P.U.C. SUBST. R (d), TNMP requests approval of its proposed Advanced Metering System Deployment Plan and approval of an AMS surcharge. Under its advanced meter deployment plan, TNMP will provide full deployment of advanced meters to approximately 240,000 retail electric customers over the period TNMP requests approval of an AMS Surcharge tariff to recover the reasonable and necessary costs it will incur under the deployment plan for the full deployment of advanced meters to residential and non-residential customers in its retail electric service area, except for those customers who have Interval Date Recorders (IDR) or take unmetered service. Q. PLEASE LIST THE COMPANY S OTHER WITNESSES AND THE TOPICS EACH WILL DISCUSS. A. Below is the list of TNMP other witnesses and the topics each will discuss. Allan Burke - Presents TNMP s deployment schedule and the effects to TNMP Operations; Gary Kessler Presents the technology solutions that are required for TNMP to successfully implement an AMS solution; Kim Morris - Presents the back-office budget requirements and assumptions to successfully implement an AMS solution; Henry Monroy - Presents the accounting requirements and assumptions to successfully implement an AMS solution; Michael Montgomery Presents the McKinsey model and cost allocation and rate design. Q. PLEASE SUMMARIZE HOW TNMP S PROPOSED AMS DEPLOYMENT PLAN MEETS THE REQUIREMENTS OF SUBST. R

51 DIRECT TESTIMONY OF STACY R. WHITEHURST PUC DOCKET NO A. TNMP's AMS Deployment Plan is attached as Attachment A to the petition and application, and is sponsored by Mr. Burke, Mr. Kessler and me. As required by P.U.C. SUBST. R (d)(4), the AMS Deployment Plan describes the following: (i) the type of meter technology; (ii) the type of communications equipment supporting the AMS; (iii) the systems to be developed during the deployment period; (iv) the timeline for the web portal deployment; (v) the deployment by specific geographical area; (vi) when posting on the website will begin; and (vii) the schedule for deployment of the web portal functionalities. The plan also includes information pertaining to the estimated costs of all the AMS components and to the contracts for equipment and services that establish the reasonableness of the plan. Q. PLEASE SUMMARIZE TNMP S REQUEST IN THIS PROCEEDING. A. TNMP is filing for Commission approval for an AMS deployment plan and an AMS surcharge. In this application, TNMP provides the testimony and supporting information of six witnesses. TNMP witnesses Kessler, Morris, Montgomery, Monroy, Burke, and myself provide actual and estimated costs for implementing AMS, the contracts for equipment and services, and estimated net operating cost-savings expected, if any. Q. DOES TNMP S DEPLOYMENT CONTAIN THE REQUIRED INFORMATION IN PUC SUBST R (d)(4) AND THE FEATURES DESCRIBED IN PUC SUBST R (g)(1)? A. Yes. TNMP witnesses Kessler, Burke, and myself support TNMP s deployment plan and describe how TNMP s deployment contains the information requested PUC SUBST. R (d) (4) and (g) (4). Q. HOW DOES TNMP S RESIDENTIAL SURCHARGE COMPARE TO THE OTHER APPROVED AMS SURCHARGES, AS WELL AS OTHER UTILITIES NON-AMS FIXED CHARGES? A. While TNMP s residential AMS surcharge is higher than Oncor, Centerpoint, AEP Texas North Company (TNC), and AEP Texas Central Company, a more appropriate comparison includes not only the AMS surcharge, but also the metering charge. Tariff Charge Centerpoint Oncor AEP TNC AEP TCC TNMP Metering Charge $ 1.79 $ 2.20 $ 5.24 $ 3.55 $ 2.20 AMS Metering Charge Total Monthly "Metering" Cost $ 5.03 $ 4.39 $ 8.39 $ 6.70 $

52 DIRECT TESTIMONY OF STACY R. WHITEHURST PUC DOCKET NO As the table demonstrates, TNMP total fixed metering costs (as defined above and if approved), would be in the range of all ERCOT utilities with a Commission-approved AMS surcharge. It is also worth noting that TNMP s AMS surcharge is less than TNC s metering charge. 5 IV. OVERVIEW OF TNMP S AMS DEPLOYMENT PLAN Q. HAS TNMP PREVIOUSLY FILED A NOTICE OF DEPLOYMENT AND STATEMENT OF FUNCTIONALITY? A. Yes. On August 4, 2009, TNMP filed a contingent notice of deployment and statement of functionality since it was seeking federal stimulus funds to expedite the deployment of advance meters in its service territory. TNMP is filing a new deployment plan, as described in Mr. Burke's testimony, with full deployment of meters in TNMP's service territory in five years. TNMP had previously proposed a full deployment within three years, which would have been possible through a 50 percent matching grant through federal stimulus funds. However, TNMP was not selected to receive such a federal grant. Q. DID TNMP S GRANT SUBMISSION CONTAIN COSTS JUST FOR THE PROPOSED DEPLOYMENT OF AMS? A. No. TNMP s application for federal stimulus funds not only included the costs for deployment of an AMS, but included cost to implement a Smart Grid. The costs for the Smart Grid included cost for SCADA (supervisory control and data acquisition) in every substation and distribution automation. TNMP has only included costs associated with the deployment of AMS. Q. DOES TNMP EXPECT TO RECEIVE FEDERAL STIMULUS FUNDS IN THE FUTURE? A. TNMP is not aware of any future opportunities to receive matching federal funds under the American Recovery and Reinvestment Act of Q. ARE THERE SPECIFIC REASONS WHY TNMP IS DEPLOYING METERS OVER A LONGER TIME PERIOD THAN COMPARED TO THE ORIGINAL NOTICE OF DEPLOYMENT? 4 52

53 DIRECT TESTIMONY OF STACY R. WHITEHURST PUC DOCKET NO A. Yes. TNMP did submit an application 1 to the Department of Energy in order to be a recipient of federal stimulus funds that would have made more funds available to TNMP for a more expedient deployment. TNMP received notification during the fourth quarter 2009 that its filing was not selected to receive a federal grant. Currently, TNMP is trying to improve its credit rating metrics 2. In addition, even though TNMP s last rate case was recently finalized with a unanimous settlement agreement, TNMP is not achieving its allowed rate of return Q. SUMMARIZE TNMP S EFFORT TO FIND AN AMS SOLUTION. A. TNMP has been seeking an AMS solution for several years, as discussed by TNMP witness Kessler. The solution has led TNMP to implement several pilot programs and demonstrations, all of which have been successful. I will describe the pilot effort and demonstration in more detail Q. PLEASE DESCRIBE TNMP S PILOT EFFORTS? A. TNMP has successfully implemented three pilot programs and has held two public demonstrations. The first pilot program consisted of 100 meters in the Clifton service area. Clifton was chosen specifically to test the communication ability and reliability, since this area is neither a highly populated nor a highly commercially developed area. In order to verify the accuracy of the meters and communications, TNMP duel-socketed these metering points to validate the data. While this initial pilot of meters does not have all the functionality of the rules 3, TNMP was able to determine that these meters could access existing cellular towers, could be remotely read, send 15-minute interval data, and send outage notifications 4. The second pilot consisted on 400 meters in metropolitan areas: the Gulf Coast service area near Houston, and the Lewisville area. While TNMP was already confident that the cellular technology would not have any coverage issues, this allowed TNMP to have results in the areas where most of its residential customers reside. Finally, TNMP installed roughly another 9,400 meters in the fourth quarter of 2009 and the first quarter of 2010; approximately 80% were installed in the Gulf Coast service territory. TNMP has been successful at reading the meters, performing move-ins and move-outs, receiving outage notifications, and receiving tampering notifications. 1 TNMP did receive confirmation that its application was complete and was considered on the merits of the technology and costs. 2 On March 9 th 2010, Moody s revised their outlook and ratings for TNMP, citing TNMP s improved cash flow. Exhibit SRW-4 3 TNMP seeks recover of these meters; since these meters will be relocated to premises that do not require disconnect or reconnect capabilities, such as certain unmetered lighting. 4 A key component of TNMP s AMS is the implementation of an outage management system. 5 53

54 DIRECT TESTIMONY OF STACY R. WHITEHURST PUC DOCKET NO Q. PLEASE DESCRIBE TNMP S PILOT DEMONSTRATION EFFORTS. A. TNMP has held two separate demonstrations; the first one was part of the REP annual in meeting in The second meeting was in 2009 for the additional members of Commission Staff that were not able to attend the REP meeting. At these meetings, TNMP was able to demonstrate the disconnect and reconnect functions, on-demand readings, and outage notifications ( from the meter) with a demonstration meter. A demonstration was also performed on a TNMP employee s 5 SmartSynch meter. Q. PLEASE PROVIDE A SUMMARY OF TNMP S ADVANCE METER TECHNOLOGY. A. As described in detail in the testimony of TNMP witness Kessler, TNMP is proposing to deploy SmartSynch s AMI Intelligence smart metering solution, which features a communications module that is integrated into several vendors electricity meters, such as GE I-210+c, Elster s REX, and Landis+Gyr Focus. The SmartMeter can communicate with C12.21 head-end systems (such as MV-90) and complies with ANSI C12.19 protocols for data storage. All SmartSynch Meters deployed transmit data using C12.22 ANSI communications. Those meters in the field that are not C12.22 compliant will be upgraded from C12.19 via an over-the-air firmware update. The meter construction and two-way communications capability will enable TNMP to process remote connects and disconnects of power service. The advanced meters have the ability to measure, store, and report both energy inflows and outflows, as necessary for net metering purposes. Deployed meters will use four channels at a minimum. This data will be available in 15-minute intervals and provide approximately 2,880 meter reads per month as opposed to the historic single read per month. These meters will also be enabled to operate with a customer s HAN device through the ZigBee wireless component. Communication with HANs allows for increased demand response and demand-side management by providing pricing signals to customers, controlling selected appliances and their usage profiles, and providing energy consumption information to consumers via the web portal or in-home monitors. They will also support a more robust and efficient OMS and coordination with distribution automation by providing voltage threshold signals to the distribution system. The ZigBee protocol will be Smart Energy compliant. Q. PLEASE PROVIDE A SUMMARY OF TNMP S COMMUNICATION TECHNOLOGY. 5 TNMP s Business Unit Director gave permission to perform the demonstration of her residence. 6 54

55 DIRECT TESTIMONY OF STACY R. WHITEHURST PUC DOCKET NO A. TNMP s meter communications will be based on the existing cellular communications network provided by AT&T. Current coverage validation by this provider indicates the majority of ESIDs have coverage within TNMP s service territory. This is covered in more detail in Mr. Kessler s testimony. The geographic diversity coupled with TNMP s smaller customer base (relative to other primary ERCOT participants) challenges the feasibility of a large capital investment for a communications infrastructure. The communications infrastructure required for the Company s service territory would be prohibitively expensive for the customer base, and consequently, cellular communication represents a cost-effective solution to smaller utilities with a geographically dispersed rural customer base. This approach is not unique in terms of technology, and represents a low-risk technological solution to Advanced Metering. For many years, Commercial and Industrial (C&I) meter reading has been done using the Plain Old Telephone System (POTS) by having a data collection system call each meter for a reading, then collecting the information and passing it on to the back-office. This has always been done for major commercial customers with complex billing requirements such as Time-of-Use, Critical Peak Pricing and Interval Pricing. TNMP s AMS solution is designed to utilize the technology created for C&I meters, simplify it, and move it to a residential form factor and small commercial application, lower the meter cost, and insert cellular telephony in place of the POTS communications. Q. HOW IS TNMP PROPOSING TO STRUCTURE THE LEVELIZED SURCHARGE? A. Like the Centerpoint and AEP (American Electric Power) approved tariffs, TNMP proposes a tiered surcharge. This surcharge is levelized for the first five years, and then is decreased and levelized over the last seven years. What makes TNMP s surcharge different is that TNMP is unable to spread the amount associated with the AMS infrastructure, excluding the meter costs, over a large population, such as Centerpoint or Oncor; nor does TNMP have a mandated refund that can be applied to offset the surcharge, as AEP TCC and AEP TNC do. Q. CAN YOU EXPLAIN WHY TNMP SEEKS A TWO-TIERED LEVELIZED SURCHARGE? A. Yes. TNMP management realizes the importance of AMS to the ERCOT market, which is designed to allow customers to have better pricing transparency; improved metrics 7 55

56 DIRECT TESTIMONY OF STACY R. WHITEHURST PUC DOCKET NO with move-ins, move-outs, disconnects, reconnects, rereads, 15-minute settlement, and monthly meter reading; and automatic outage notifications. For TNMP, this is a project outside the normal transmission and distribution budget. This is not an example of shifting budget dollars from one project to another or adding budget dollars back into the budget that were previously cut. Over the last five years, TNMP has continued to invest in its distribution and transmission system 6. However, due to TNMP s lower credit ratings and the effect that negative cash flows have on the company s credit metrics, the company has developed a two-tier levelized surcharge that would minimize those effects. 7 Agency Rating Outlook S&P BBB- Stable Moody's Baa1 Stable Fitch BBB Stable Without significant and sustained improvement to its credit metrics, TNMP may be facing a credit downgrade which has significant consequences to the Company and its customers. Access to credit will be severely restricted and the cost of additional debt will be significantly more expensive if TNMP were to be downgraded to below-investment grade. TNMP seeks a future in which it can help to bring a smarter grid to its service area and the many small and rural communities included in this service area. This two- tier levelized surcharge will accomplish that goal. A two-tiered levelized surcharge was approved by the Commission for TCC and TNC 8 and Centerpoint V. COMPLIANCE WITH THE COMMISSION S ADVANCE METER RULE Q. PLEASE SUMMARIZE HOW THE AMS PROPOSED BY TNMP MEETS THE FUNCTIONALITY REQUIREMENTS OF SUBST. R A. As discussed by TNMP witnesses Kessler and Burke, TNMP s AMS technology: (i) involves meter technology that will be able to implement automated or remote meter reading; (ii) will allow two-way communication; (iii) will allow remote disconnect and reconnect for meters rated at or below 200 amps; (iv) will have the capability to timestamp data; (v) will have the capability to provide direct access to consumer usage data 6 On March 4, 2010, TNMP filed for an interim transmission cost of service filing as contemplated under PUC Substr The increase on nearly $34 million in transmission plant addition between Apr 2008 and Dec Exhibit SRW-4 8 Docket No

57 DIRECT TESTIMONY OF STACY R. WHITEHURST PUC DOCKET NO to the REP and end-use consumer; (vi) will have the means to furnish price signals; (vii) will have the capability to provide 15-minute data to ERCOT; (viii) will provide on board meter storage capability meeting ANSI C12.19, (ix) will accommodate open standards and protocols that meet nationally recognized standards; (x) will have the capability to communicate with devices within the home based on open standards and protocols; and (xi) will provide the ability to upgrade these minimum capabilities as technology advances. Q. DOES TNMP S PROPOSED AMS DEPLOYMENT ALLOW FOR AUTOMATED OR REMOTE METER READINGS 10? A. Yes. TNMP s current pilot meters are being remotely read on a monthly basis for billing. TNMP s witness Kessler discusses how TNMP s AMS technology performs this requirement. Q. DOES TNMP S PROPOSED AMS DEPLOYMENT ALLOW FOR TWO-WAY COMMUNICATION 11? A. Yes. TNMP s current pilot meters can receive communication from TNMP to perform a monthly or off-cycle meter reading, can energize or re-energize the service point, and can receive other type of communication sent by TNMP. In addition, the meters can communicate back to TNMP. The meters can send meter readings, tampering notifications and outage notifications. TNMP s witness Kessler discusses how TNMP s AMS technology performs this requirement. Q. DOES TNMP S PROPOSED AMS DEPLOYMENT ALLOW FOR REMOTE DISCONNECTION AND RECONNECTION CAPABILITY FOR METERS RATED AT OR BELOW 200 AMPS 12? A. Yes. TNMP s current pilot meters have remotely disconnected or remotely executed a turn-off and performed reconnection or remotely executed a move-in. TNMP s witness Kessler discusses how TNMP s AMS technology performs this requirement. TNMP will seek several waivers on this requirement, which I discuss later in my testimony. Q. DOES TNMP S PROPOSED AMS DEPLOYMENT ALLOW FOR TIME-STAMP DATA SENT TO ERCOT 13? 9 Docket No PUC Subst R (g)(1)(A) 11 PUC Subst R (g)(1)(B) 9 57

58 DIRECT TESTIMONY OF STACY R. WHITEHURST PUC DOCKET NO A. Yes. TNMP s current pilot meters are unable to send 15-minute interval directly to ERCOT. TNMP s pilot meters monthly meter reading data is being pulled and summarized for billing in TNMP s existing billing system. In order for TNMP to meet this requirement, TNMP is requesting approval and recovery of a meter data management system. TNMP s witness Kessler discusses the meter data management system and the necessity to be included as part of TNMP s deployment plan and surcharge. Q. DOES TNMP S PROPOSED AMS DEPLOYMENT ALLOW CUSTOMERS TO HAVE ACCESS TO USAGE DATA AND WILL ALLOW USAGE DATA TO BE POSTED ON THE JOINT TDSP WEB PORTAL 14? A. TNMP seeks a waiver from P.U.C. SUBST. R (g) (1) (E) (i) if and only to the extent those rules require real-time access to data for end-use customers. End-use customers will not have access to data through a web portal unless and until (A) provided by their REP, or (B) the Texas common data repository (hereinafter, Common Repository) and Texas common web portal (hereinafter, Common Portal) are in place pursuant to the Implementation Project Relating to Advanced Metering, Project No Once the Common Portal is completed, customers (in addition to REPs and authorized third parties) will have secure access to data through the Common Portal. TNMP will provide interval data to the joint web portal, as described by TNMP witness Kessler. Q. DOES TNMP S PROPOSED AMS DEPLOYMENT ALLOW REPS TO SEND PRICE SIGNALS TO THE CUSTOMER 15? A. Yes. TNMP s AMS deployment allows for the use and communication to a home area network (HAN) energy monitoring device. A HAN energy monitoring device will allow customers to track daily usage against their budgets and take action to conserve before the billing period ends. Some energy monitors also allow the consumer to track usage against historical usage for the period. These monitors also can be used to communicate dynamic price signals from the REP to the consumer, as well as to provide demand response signals. TNMP s witness Kessler discusses how TNMP s AMS technology performs this requirement. 12 PUC Subst R (g)(1)(C) 13 PUC Subst R (g)(1)(D) 14 PUC Subst R (g)(1)(E) 15 PUC Subst R (g)(1)(F) 10 58

59 DIRECT TESTIMONY OF STACY R. WHITEHURST PUC DOCKET NO Q. DOES TNMP S PROPOSED AMS DEPLOYMENT ALLOW FOR 15-MINUTE INTERVAL DATA TO BE PROVIDE TO REPS, CUSTOMERS, ERCOT, OR THE JOINT TDSP WEB PORTAL ON A DAILY BASIS 16? A. TNMP s current pilot meters are unable to send 15-minute VEEE (Validate, Edit and Estimate) interval directly to ERCOT. TNMP s pilot meters monthly meter reading data is being extracted and summarized for billing in TNMP s existing billing system. In order for TNMP to meet this requirement, TNMP is requesting approval and recovery of a meter data management system. TNMP s witness Kessler discusses the meter data management system and the necessity to be included as part of TNMP s deployment plan and surcharge. TNMP is only able to meet the requirement of this section of the rule with the approval of the back-office solution, as discussed by Mr. Kessler. Q. DOES TNMP S AMS DEPLOYMENT HAVE ON-BOARD STORAGE THAT COMPLIES WITH ANSI C12.19 TABLES AND OPEN STANDARDS AND PROTOCOLS THAT COMPLY WITH ANSI C12.22 STANDARDS 17? A. Yes. TNMP s witness Kessler discusses how TNMP s AMS technology performs these requirements. Q. DOES TNMP S AMS DEPLOYMENT ALLOW FOR THE COMMUNICATION WITH DEVICES INSIDE THE HOME THROUGH OPEN STANDARDS SUCH AS ZIGBEE OR HOME PLUG 18? A. Yes. TNMP s witness Kessler discusses how TNMP s AMS technology performs these requirements. Q. DOES TNMP S AMS DEPLOYMENT ALLOW FOR UPGRADE THESE MINIMUM CAPABILITIES AS TECHNOLOGY ADVANCES 19? A. Yes; upgrades can be accomplished over the air. TNMP s witness Kessler discusses how TNMP s AMS technology performs these requirements. Q. IS TNMP PROPOSING ANY WAIVERS AS CONTEMPLATED BY PUC SUBST. R (g)(3)? A. Yes. I will identify the waivers TNMP requests later in my testimony. 16 PUC Subst R (g)(1)(G) 17 PUC Subst R (g)(1)(H) and PUC Subst R (g)(1)(I) 18 PUC Subst R (g)(1)(J) 19 PUC Subst R (g)(1)(K) 11 59

60 DIRECT TESTIMONY OF STACY R. WHITEHURST PUC DOCKET NO Q. WHERE WILL TNMP S ELECTRICITY DEPLOYMENT PLAN MADE AVAILABLE? A. Besides TNMP s AMS website, which is not currently created, TNMP s deployment plan will be available at 1005 Congress Avenue, Suite 550, Austin, Texas. In addition, the deployment plan will be available at 225 E. John Carpenter Freeway Suite 1500, Irving, Texas. Market participants who wish to view the deployment plan in Austin will need to provide advance notice, since this office is not fully staffed on a regular basis. 7 VI. WAIVERS A. As identified in TNMP s statement of functionality, TNMP requests waivers for the following: Waiver on disconnection: Loads that may cause a safety or health issue if disconnected will not have an advanced meter with disconnect functionality installed. For example, TNMP proposes not to include the disconnection function for traffic lights, metered streetlights, railroad crossings, police stations, hospital facilities, service points providing cathodic protection, and TNMP s emergency facilities. Loads that currently have poly-phase and/or higher than class 200 (200 amp rating) meters will not have a disconnect device until poly-phase advanced meters with a disconnect device are available in the market Waiver on HAN requirements: Loads that do not require and will never require HAN device will not have an advanced meter with a HAN device installed. For example, TNMP proposes not to include a HAN device for metered streetlights and other applications that would not benefit from a HAN device, such as electric gates, communications power supplies, sprinkler controls, and cathodic protection power supplies. Loads that have poly-phase and instrument rated meters will not have a HAN device until those advanced meters with HAN devices are available in the market. Waiver on replacement outside of deployment plan: TNMP not be required to install advanced meters under the circumstances set forth in P.U.C. SUBST. R (g) (6), in advance of the full deployment of advanced meters in a given area. TNMP will make efforts to install AMS meters on new meter installs. Waiver on access to usage: TNMP seeks any and all waivers required from P.U.C. SUBST. R (g) (1) (E) (i) and (G) if and only to the extent those rules require real-time access to data for end-use customers. End-use customers, however, will not have access to data through a web portal unless and until (A) provided by their REP, or (B) the Texas common data repository 12 60

61 DIRECT TESTIMONY OF STACY R. WHITEHURST PUC DOCKET NO (hereinafter, Common Repository) and Texas common web portal (hereinafter, Common Portal) are in place pursuant to the Implementation Project Relating to Advanced Metering, Project No Once the Common Portal is completed, customers (in addition to REPs and authorized third parties) will have secure access to data through the Common Portal. Q. ARE THERE ANY OTHER WAIVERS THAT TNMP REQUESTS? A. Shortly after this filing, TNMP will be filing a general base rate proceeding as contemplated by PUC SUBST. R (k) (4). TNMP requests a waiver to moving any AMS costs into base rate until TNMP has fully executed its deployment plan. Until TNMP has fully deployed AMS throughout its service area, TNMP will not be able to have a proper baseline for costs that will be used in any reconciliation proceeding. 14 VII. TNMP S CUSTOMER EDUCATION PLAN Q. DID TNMP INCLUDE EXPENSES EARMARKED FOR CUSTOMER EDUCATION? A. Yes, as an integral part of the Company s AMS deployment plan, TNMP is implementing a customer education program that is designed to reach customers who will be receiving an advanced meter. Through this program, TNMP is seeking to educate those customers about the benefits of advanced metering technology and how this capability can potentially help customers save energy and money, as well as provide better system reliability. A key message for TNMP is that during the installation of the new meters, TNMP will be photographing the old meter and new meter reading, and performing an audit on 100 percent of the meter replacements. TNMP s customer education program is centered on various customer outreach tools, such as community events, presentation materials (chamber meetings or city council forums), and electronic communications. Customers will receive several information sources that will provide an overview of TNMP and its role in the community, TNMP s use of technology to improve electric delivery and reliability, and information about what the advanced meter means for consumers. Q. WHAT TYPE OF MESSAGE IS TNMP S CUSTOMER EDUCATION TRYING TO SEND? A. TNMP is installing advanced meters in homes and buildings across its Texas service areas. Some of these areas are not in highly populated areas; in fact, except the 13 61

62 DIRECT TESTIMONY OF STACY R. WHITEHURST PUC DOCKET NO Lewisville and Gulf Coast service territory, most of the customers are in rural areas. The deployment process will take place from 2010 through 2015 to prepare the state to manage the ever-increasing energy needs of the future. TNMP s customers need to understand that this rollout is part of a long-term statewide initiative, led by the Texas Public Utility Commission and the Texas Legislature, to upgrade from analog to digital meter technology. This rollout will lay the foundation for customer programs that can reduce energy consumption, decrease energy costs through new pricing programs by REPs, and create new energy efficiencies opportunities. While TNMP s role in the Energy Chain is limited to owning and maintaining power lines, providing customer education before, during, and after the deployment is critical to minimize customer confusion and educate customers on the benefits of advanced meters. Specifically, TNMP s customer education plan: 1) explains what a smart meter is; 2) explains the difference between a smart meter compared to a customer s existing meter; 3) helps the customer understand how a smart meter works in a smart grid; 4) explains TNMP s technology; 5) addresses the timing and deployment schedule; 6) shares the benefits to TNMP and customers; and, 7) explains the security/privacy of smart meters. The detail of a potential educational message is below. Smart Meters A Smart Meter is a device attached to a home or building that digitally reads and captures energy usage. A Smart Meter is one of the latest technologies that will enable consumers to better monitor and track energy use, and make more informed decisions on energy consumption. Smart Meters vs. Analog Meters While the traditional, manual, analog meters have served Texas well, the Smart Meter digital technology is far more reliable, secure and accurate. It s a necessary evolution of technology to complement the state of Texas future plans for a smarter, more efficient energy system. Accuracy As identified in Mr. Burke s testimony, TNMP has identified several key steps to ensure the accuracy of the meter exchange process. Before the meter exchange process occurs, 100 percent of the new meters have been tested by General Electric and SmartSynch. In addition, TNMP performs an audit of a sample from every pallet of meters. TNMP s outside vendor is responsible for capturing the out reading of the old meter and the in reading of the new meter with a digital camera. These digital images will be audited. This audit includes 100 percent verification of all out readings and in readings before submission to TNMP for billing

63 DIRECT TESTIMONY OF STACY R. WHITEHURST PUC DOCKET NO Finally, TNMP s billing system has a built in high/low meter reading verification that compares current consumption to be billed with historical consumption, if available. Smart Grid A smart grid is an intelligent power transmission and distribution network that controls the flow of electricity and data. It s the future of our country and state s energy infrastructure. A smart grid will increase real-time data and two-way communication with end users and utility resources. The ultimate vision for Texas smart grid is to enable future technologies, reduce energy costs, integrate renewable energy sources and improve system reliability. Smart Meters and Smart Grid Smart Meters are the most visible aspect of a smart grid to consumers, although they are just one component of Texas commitment to a more sophisticated energy system. A Smart Meter will produce an enormous amount of data, capturing power usage every 15-minutes, and reporting this back to the utility company hourly or daily. Information from Smart Meters will allow for the continued development of a smart grid for Texas. The Technology Smart Meters use two-way technology to talk through the existing cellular network infrastructure and send real-time meter data to customers, grid operators and utility companies. Eventually, the technology will allow sophisticated home appliances, energy systems and the Smart Meter to talk to each other. TNMP s Smart Meters utilize proven GSM cellular technology. The network provider is AT&T. Timing and Deployment Now through 2015, TNMP is installing Smart Meters for all residential and commercial users in TNMP s service areas across Texas. The switch to this advanced meter technology will allow for a more efficient and effective means of utility distribution and consumption. TNMP has planned a 5-year Smart Meters deployment, from 2010 to 2015, as part its aggressive but fiscally responsible timeline to allow all residential and commercial users the opportunity to benefit from this technology as soon as possible. TNMP s phased rollout begins along the Gulf Coast in 2010, followed by North Texas and Central Texas in 2013, and concluding in West Texas in This timeline was established to reach the greatest number of people as quickly as possible and to ensure a smooth transition for all involved. Benefits The Smart Meters real-time, digital technology will send more accurate energy usage readings to utility companies, arming them with data to better serve customers. Capability to provide 15-minute interval data vs. the traditional once-a-month meter read to utility companies improved trouble-shooting capabilities for power disruptions. Less intrusive; remote 15 63

64 DIRECT TESTIMONY OF STACY R. WHITEHURST PUC DOCKET NO reading capability reduces need to access meter on property Enhanced reliability and speed for connection changes. Consumers will have access to real-time energy usage. Consumers will have capability to remotely communicate with in-premise devices to control energy usage, which will enhance efficiency to meet energy demand without adding resources, like power plants. TNMP will have the ability to remotely upgrade Smart Meters with future technologies. REPs will have the opportunity to offer more dynamic pricing, including peak pricing and peak pricing rebates. Security/Privacy of Smart Meters TNMP is committed to the highest standards of privacy and security for consumers energy usage data. Smart Meters inherently are more secure, protected and precise than traditional, analog meters. The digital technology provides more accurate reads to the utility company which will result in pass-along benefits to the end user. Over time, consumers will have the opportunity to access specific personal energy usage information via a secure and password-protected Web portal. Cost Responsibility TNMP is committed to launching Smart Meters across its Texas communities in the most fiscally responsible manner, ever cognizant of the consumer costs involved. The Texas Public Utility Commission has approved a monthly consumer surcharge to cover the cost involved for this technology rollout for 12 years. Advanced meters are a small investment for Texans for more responsible energy system in the future. Texans will see the financial and environmental benefits from this technology for decades to come. Cost Details Beginning in 2010, consumers who receive power from TNMP will see a minimal surcharge on their monthly electric bills. This 12-year surcharge will offset the costs involved to bring this technology to Texas residences and commercial facilities. To offset the cost involved, consumers are encouraged to become more energy efficient at home and at work, including changing bulbs to compact fluorescent lights and unplugging appliances/devices when not in use. Q. PLEASE DESCRIBE HOW THE CUSTOMER EDUCATION WILL BE IMPLEMENTED. A. Since the majority of TNMP s advance meter deployment will be on residential premises, TNMP is implementing a customer education campaign that takes the form of two character mascots: Kilo and Wattson. TNMP will roll out the customer education in areas before the deployment actually occurs, (using the same area identified in the deployment plan). The education process within the Gulf Coast service territory will begin before the January 1, 2011, deployment 16 64

65 DIRECT TESTIMONY OF STACY R. WHITEHURST PUC DOCKET NO and will end in West Texas during Throughout the customer education rollout, Kilo and Wattson will serve as mascots of the campaign, appealing to all ages and demographics. They are non-threatening vehicles to deliver the TNMP smart meter rollout using a down-to-earth message. The Kilo & Wattson campaign will focus on community events in order to spread the Smart Meter message. Q. FOR THE INITIAL CUSTOMER EDUCATION ROLLOUT, PLEASE DESCRIBE THE COMMUNITY EVENTS THAT WILL HAVE THE TARGETED MESSAGING. A. The types of events will be dictated based on the location of future deployment and scheduled community events. In the Gulf Coast area, in Alvin, the community events identified are high school football games, the 5 th Annual SplashMania, FishFest, Frontiers Day, and Crawfish Festival. In Friendswood, the community events identified are the Holiday Hustle and Houston Rodeo. In Angleton, the community events identified are the Brazoria County Fair, Festival of Lights, Fall Family Fest, Heart of Christmas, and the Jingle Bell Run. In League City, the community events identified are the American Cancer Society s Pink Ladies golf tournament, Mardi Gras Galloway Gallop and Yachty Gras, Events at Kemah boardwalk, Spring Break celebration, Corvette Show and Crawfish festival, the Village Fair, and the Texas music festival. For Texas City, the community events identified are the Fun Fest, Chamber Golf Classic, and Music Fest by the Bay. Q. WHY IS TNMP CHOOSING EVENTS SUCH AS THESE? A. Whether it is a high school football game or season event, TNMP s involvement in community events will allow for deeper penetration in the various markets, thus increasing exposure and educational opportunities. Q. WHAT TYPES OF COSTS ARE ASSOCIATED WITH THIS TYPE OF EDUCATION CAMPAIGN? A. Please see EXHIBIT SRW-2 which is the detailed proposal, which has been incorporated into the McKinsey Model. 28 VIII. TNMP MCKINSEY MODEL ASSUMPTIONS Q. ARE YOU TESTIFYING ON SOME OF THE ASSUMPTIONS MADE THAT ARE USED IN THE MCKINSEY MODEL? 17 65

66 DIRECT TESTIMONY OF STACY R. WHITEHURST PUC DOCKET NO A. Yes. In this section of my testimony, I will address some of the assumptions that were used in the CustomerServiceBenefits tab in the model. Mr. Burke will discuss the Meter Reading Savings in his testimony. Q. DID TNMP INCLUDE ANY SAVINGS ASSOCIATED WITH BILLING SAVINGS A. While one of the primary benefits of AMS is automated meter readings, and therefore taking the human element out of the equation, TNMP does not expect to see any billing savings. Currently TNMP s billing department handles daily billing exceptions and, these billing exceptions do not include any exceptions that were caught and corrected in the hand held that are used by meter readers. TNMP believes that these billing exceptions will still occur, because of the validation in the billing system, which tries to determine high/low billing exceptions before an invoice is sent to the REP. In addition to working billing exceptions, TNMP s billing department also performs the complex billing review of industrial bills and analysis and resolutions to MarkeTrak 20. These functions will not be eliminated due to the implementation of AMS. Q. DID TNMP INCLUDE ANY SAVINGS ASSOCIATED WITH CREDIT AND COLLECTION OR THEFT PREVENTION A. No. The ERCOT market billing structure does not lend itself to any savings associated with credit and collections. TNMP s customer is the REP and not the individual tenant at a business or residence. Therefore TNMP s customers are limited to the 70 REPs in TNMP service territory, and not the approximately 240,000 individual points where the advance meters will be installed. TNMP s billing group is the responsible group for handling REP defaults. Currently, TNMP does not maintain a revenue protection or theft prevention department; therefore the McKinsey Model included cost for additional headcounts, as discussed by TNMP witness Burke, since meter readers will not be viewing every meter each month. Q. IN GENERAL, WHAT WILL HAPPEN TO ANY ACTUAL SAVINGS THAT ARE GREATER THAN THOSE ESTIMATED IN THE AMS SURCHARGE MODEL? A. To the extent any additional savings are realized, they will be passed on to consumers either through a reduced discretionary fee, as part of the AMS reconciliation proceeding, or in a base rate case. 20 MarkeTrak tracks ERCOT retail market issues and data discrepancies

67 DIRECT TESTIMONY OF STACY R. WHITEHURST PUC DOCKET NO. 1 IX. ADDITIONAL REQUESTS Q. ARE THERE ANY OTHER DETAILS OF TNMP AMS DEPLOYMENT THAT THE COMMISSION NEEDS TO APPROVE? A. Yes. TNMP has included costs associated with in-home devices for approximately 13,000 low income customers, and requests the Commission approve an accelerated depreciation of the existing analog and load research meters. Q. IS TNMP SEEKING RECOVERY OF COSTS THAT HAVE BEEN INCURRED AS A RESULT OF THE IMPLEMENTATION OF THE COMMISSION S AMS RULE THROUGH PROJECT NO ? A. Yes. Under P.U.C. SUBST. R (k)(1), the Commission:... shall establish a nonbypassable surcharge for an electric utility to recover reasonable and necessary costs incurred in deploying AMS to residential and non-residential customers other than those required by the independent system operator to have an interval demand meter. The surcharge shall not be established until after a detailed Deployment Plan is filed pursuant to subsection (d) of this section. In addition, the surcharge shall not ultimately recover more than the AMS costs that are spent, reasonable and necessary, and fully allocated, but may include estimated costs that shall be reconciled pursuant to paragraph (6) of this subsection TNMP s participation in the AMS implementation project, including sharing the funding of Solution s Cube, (consultants retained by the Commission) are reasonable and necessary to the proposed AMS deployment and are reasonable and necessary to ensure deployment consistent with the Commission s expectations. In the absence of AMS deployment, TNMP would not incur these costs. Q. IS TNMP SEEKING RECOVERY OF ESTIMATED COSTS FOR PROCESSING THIS CASE AT THE COMMISSION? A. Yes. Similar to the other utilities that have filed for an AMS surcharge, TNMP has included estimated TNMP legal costs, noticing costs, and travel costs in the event this case goes to hearing. If the case does not go to hearing, then these costs will need to be reconciled. This estimate does not include any amount associated with any cost that Cities with original jurisdiction may seek to collect from TNMP. If Cities that have retained original jurisdiction seek repayment of consultant and legal fees, TNMP will seek to recover these costs from the customers in these cities through an AMS rate case expense surcharge. In addition, due to cash flow impacts, TNMP seeks approval to 19 67

68 DIRECT TESTIMONY OF STACY R. WHITEHURST PUC DOCKET NO reimburse Cities over the time period that an AMS rate case expense surcharge is in effect. Q. PLEASE DESCRIBE THE COSTS ASSOCIATED WITH IN-HOME MONITORS? A. Advance meters will allow customers to receive information on their energy use; allow customers to change their energy consumption patterns; and allow customers to receive price signals from REPs. To give low-income customers the opportunity to receive some of the benefits from AMS, TNMP has included the costs for approximately 13,000 inhome monitors to be distributed to the 13,000 customers that have been identified as receiving the low-income discount. This economic class of customers might not normally spend the money on an in-home monitor. It is TNMP s goal for the AMS surcharge to include the cost of an in-home device, chosen by Commission Staff or the shareholder process, and be available to low-income customers. Q. WITH THE DEPLOYMENT OF ADVANCE METERS, IS TNMP REQUESTING APPROVAL FOR ACCELERATING THE DEPRECIATION OF ITS EXISTING METERS? A. Yes. The Advance Metering rule allows for reasonable recovery of any non-ams metering equipment that has not yet been fully depreciated. In fact, the Commission has identified the amortization of advanced meters in the range from five to seven years, depending on the useful life of the meter. Therefore, consistent with P.U.C. SUBST. R (k), TNMP requests approval to amortize the existing non-ams meters over five years in its next general rate proceeding initiated after the filing of this docket. Q. IS TNMP IMPLEMENTING A NEW RATE RIDER FOR THE AMS SURCHARGE? A. Yes. Please see EXHIBIT SRW-3. This rider is based on Oncor s approved rider. Q. WHICH TNMP RATE CLASSES WILL BE AFFECTED BY THE AMS SURCHARGE? A. The following TNMP rate classes will be affected by the AMS Surcharge: Residential, Secondary Less Than or Equal to 5 kw, Secondary Greater Than 5 kw Non-IDR, Primary Non-IDR, and Schedule VI - Metered Lighting. Q. DO THE CLASSIFICATIONS FOR THE PROPOSED AMS CLASSES COINCIDE WITH THE AVAILABILITY FOR EACH RATE SCHEDULE INCLUDED IN TNMP S TARIFF? A. Yes

69 DIRECT TESTIMONY OF STACY R. WHITEHURST PUC DOCKET NO Q. WERE ANY CLASSES OF CUSTOMERS EXCLUDED FROM THE CALCULATION OF THE AMS COST RECOVERY FACTORS? A. No rate classes were excluded, but a subset of customers, those customers that have an interval data recorder installed, are excluded as required under PUC. Substr. R (k)(1) X. CONCLUSION Q. WHAT ACTION DO YOU PROPOSE THAT THE COMMISSION TAKE IN THIS PROCEEDING? Substantive Rule authorizes electric utilities to assess a nonbypassable surcharge to recover costs incurred for deploying advanced metering systems that are consistent with the rule. TNMP is requesting approval of a Rider AMCRF, a two-tiered levelized surcharge that minimizes negative cash flow, and approval for accelerated depreciation on its existing meters in the TNMP s next rate case after the filing of this proceeding. TNMP requests an effective date of the earlier of the first billing cycle following a final order or November 1, 2010, for the new AMS surcharge. Q. DOES THIS CONCLUDE YOUR TESTIMONY? A. Yes, it does

70 70

71 EXHIBIT SRW-1 STACY R. WHITEHURST Education Background and Business Experience Stacy R. Whitehurst is the Supervisor of Texas Regulatory Policy in the Regulatory Policy department at PNMR Services Company a subsidiary of PNM Resources, Inc. Mr. Whitehurst graduated from Texas A&M University in 1994 with a Bachelor s Degree in Political Science. Mr. Whitehurst has been employed in the electric utility industry since 2000, when Mr. Whitehurst took a position as a senior analyst with Texas-New Mexico Power Company. In this capacity, he was responsible for creation of and modifications to TNPE's customer information and billing systems to support the deregulation of electricity. In August 2003, Mr. Whitehurst took a position in the Regulatory Affairs department as a Senior Analyst. After the acquisition of TNP Enterprises by PNM Resources on June 6, 2005, Mr. Whitehurst took his current position. Proceedings in Which Stacy R. Whitehurst Filed Testimony JURISDICTION DOCKET NO. DESCRIPTION Texas Application of Texas-New Mexico Power Company, First Choice Power, Inc. and Texas Generating Company, L.P. to Finalize Stranded Costs under PURA Texas Application of First Choice Power Special Purpose, LP to Increase Its Price To Beat Fuel Factors Texas Application of Texas-New Mexico Power Company to Adjust the Competition of Transition Charge Pursuant to PURA (g) Texas Application of First Choice Power Special Purpose, L.P. to Adjust Its Price To Beat Base Rates Pursuant to PURA and PUC Subst. R (g)(3) Texas Staff's Petition to Initiate a Generic Proceeding to Re- Allocate Stranded Costs pursuant to PURA (f) Texas Petition Of PNM Resources, Inc. and Cap Rock Energy Corporation Regarding Proposed Merger and Acquisition of Stock Texas Application Of Texas-New Mexico Power Company For Authority To Change Rates Texas Application Of Texas New Mexico Power Company For Approval Of An Energy Efficiency Cost Recovery Factor 71

72 Confidential Exhibit SRW-2 Customer Education Campaign & Pricing Filed Confidential 72

73 Exhibit SRW 3 TEXAS-NEW MEXICO POWER COMPANY TARIFF FOR RETAIL DELIVERY SERVICE 6.1. Rate Schedules Applicable: Entire Certified Service Area Effective Date: November 1, 2010 Page No.: 129 Original RIDER AMCRF ADVANCED METERING COST RECOVERY FACTOR APPLICATION Applicable, pursuant to PURA (h) and Substantive Rule , to Retail Customers receiving metered service for which the Company will install and Advanced Metering System ( AMS ) at any time during the AMS cost recovery period approved by the Public Utility Commission of Texas. Rider AMCRF is not applicable to Retail Customers whose: (1) load is required to be metered by an interval data recorder meter by the independent System Operator (ERCOT), (2) load was metered by and interval data recorder meter prior to the effective date of PUCT Substantive Rule (May 30, 2007), or (3) load is unmetered. NET MONTHLY BILL AMOUNT The AMCRF for each of the Company s applicable retail rate schedules is as follows: Year 1-5 Year 6-12 Rate Schedule Surcharge Surcharge Residential Service $ 4.80 $ 4.17 Per ESI ID per month Secondary Service Less than or Equal to 5 kw $ 5.00 $ 5.00 Per ESI ID per month Secondary Service Greater than 5kW $ $ - Per ESI ID per month Primary Service $ $ - Per ESI ID per month Lighting Service (Metered Facilities) $ $ - Per ESI ID per month NOTICE This rate schedule is subject to the Company s Tariff and Applicable Legal Authorities. 73

74 EXHIBIT SRW-4 PAGE 1 of 3 Rating Action: Moody's revises outlook of PNM Resources, PNM & TNMP to stable Global Credit Research - 09 Mar 2010 Approximately $2.5 billion of securities and loans affected New York, March 09, Moody's Investors Service changed the rating outlook of PNM Resources, Inc. (PNMR: senior unsecured Ba2) and its subsidiaries Public Service Company of New Mexico (PNM: senior unsecured Baa3) and Texas-New Mexico Power Company (TNMP: senior unsecured Baa3), to stable from negative. In addition Moody's upgraded the senior secured obligations of TNMP to Baa1 from Baa2 and withdrew the (P) B1 rating assigned to a PNMR shelf registration for preferred stock that has expired. All other ratings of PNMR, PNM (including the Baa1 rating assigned to its $65 million secured pollution control revenue bonds), and TNMP are affirmed. "The stable outlook for PNMR, PNM and TNMP considers the companies' improved financial and operating performance, including its progress on debt reduction and success in achieving regulatory outcomes that are reasonably supportive of credit quality," said Laura Schumacher, Vice President/Senior Analyst. "As a result, assuming a continued focus on efficient utility operations, we anticipate the companies will be able to sustain financial credit metrics within the ranges appropriate for their ratings and risk profiles." The stable outlook also considers improvement in the liquidity profile of TNMP. The upgrade of secured debt at TNMP follows Moody's August 2009 upgrade of the majority of its senior secured debt ratings of investment grade regulated utilities by one notch. Issuers with negative outlooks were excluded from the August upgrade. During 2009, PNMR's total consolidated debt burden was reduced by about $560 million. While the majority of this reduction came as result of PNM's sale of its gas utility assets, which generated cash proceeds of approximately $525 million after tax, improved performance by PNMR's unregulated retail energy provider in Texas also contributed to a reduction in parent level debt of about $270 million. Improved cash flow at PNM comes in part as a result of an emergency fuel cost recovery mechanism put in place in 2008, along with a 2009 rate increase and approval of a more permanent fuel cost recovery mechanism. TNMP's cash flow improved, in part, as a result of its 2009 rate increase that was calculated based on among other things, actual interest expense resulting from its 2009 refinancing; as part of this decision the utility received authorization for formulaic rate making for transmission investment. The execution of a separate $75 million secured credit facility at TNMP significantly improved the utility's liquidity profile. Going forward, we expect PNM and TNMP to demonstrate credit metrics that are appropriate for utilities rated at the lower end of the Baa rating range indicated in Moody's August 2009 Rating Methodology for Regulated Electric and Gas Utilities. For example, we anticipate the utilities' ratios of cash flow excluding the impact of working capital changes to debt to remain in the low to mid teens, with the potential for further improvement dependent on additional regulatory support. While PNMR may demonstrate metrics similar to those of PNM and TNMP, its rating reflects the additional volatility of its unregulated businesses as well as the still significant amount of parent company leverage. Moody's last rating action for TNMP occurred March 16, 2009 when a senior secured rating was assigned. Moody's last rating actions for PNMR, PNM and TNMP occurred March 4, 2009 when the ratings were affirmed and the outlooks remained negative after those of PNMR and PNM were changed on April 25, The principal methodology used in rating PNMR, PNM and TNMP was Rating Methodology: Regulated Electric and Gas Utilities, published August 2009 and available on in the Rating Methodologies sub-directory under the Research and Ratings tab. Other methodologies and factors that may have been considered in the process of these issuers can also be found in the Rating Methodologies sub-directory on Moody's website. Headquartered in Albuquerque, New Mexico, PNMR is a holding company which has as its primary subsidiaries, PNM, TNMP and First Choice Power, a Texas retail energy provider. PNMR also owns a 50% interest in Optim Energy, through which PNMR conducts unregulated energy operations primarily within the Electric Reliability Council of Texas (ERCOT). 74

75 EXHIBIT SRW-4 New York Laura Schumacher Vice President - Senior Analyst Infrastructure Finance Group Moody's Investors Service JOURNALISTS: SUBSCRIBERS: New York William L. Hess Managing Director Infrastructure Finance Group Moody's Investors Service JOURNALISTS: SUBSCRIBERS: PAGE 2 of 3 Copyright 2010, Moody's Investors Service, Inc. and/or its licensors including Moody's Assurance Company, Inc. (together, "MOODY'S"). All rights reserved. CREDIT RATINGS ARE MOODY'S INVESTORS SERVICE, INC.'S ("MIS") CURRENT OPINIONS OF THE RELATIVE FUTURE CREDIT RISK OF ENTITIES, CREDIT COMMITMENTS, OR DEBT OR DEBT-LIKE SECURITIES. MIS DEFINES CREDIT RISK AS THE RISK THAT AN ENTITY MAY NOT MEET ITS CONTRACTUAL, FINANCIAL OBLIGATIONS AS THEY COME DUE AND ANY ESTIMATED FINANCIAL LOSS IN THE EVENT OF DEFAULT. CREDIT RATINGS DO NOT ADDRESS ANY OTHER RISK, INCLUDING BUT NOT LIMITED TO: LIQUIDITY RISK, MARKET VALUE RISK, OR PRICE VOLATILITY. CREDIT RATINGS ARE NOT STATEMENTS OF CURRENT OR HISTORICAL FACT. CREDIT RATINGS DO NOT CONSTITUTE INVESTMENT OR FINANCIAL ADVICE, AND CREDIT RATINGS ARE NOT RECOMMENDATIONS TO PURCHASE, SELL, OR HOLD PARTICULAR SECURITIES. CREDIT RATINGS DO NOT COMMENT ON THE SUITABILITY OF AN INVESTMENT FOR ANY PARTICULAR INVESTOR. MIS ISSUES ITS CREDIT RATINGS WITH THE EXPECTATION AND UNDERSTANDING THAT EACH INVESTOR WILL MAKE ITS OWN STUDY AND EVALUATION OF EACH SECURITY THAT IS UNDER CONSIDERATION FOR PURCHASE, HOLDING, OR SALE. ALL INFORMATION CONTAINED HEREIN IS PROTECTED BY LAW, INCLUDING BUT NOT LIMITED TO, COPYRIGHT LAW, AND NONE OF SUCH INFORMATION MAY BE COPIED OR OTHERWISE REPRODUCED, REPACKAGED, FURTHER TRANSMITTED, TRANSFERRED, DISSEMINATED, REDISTRIBUTED OR RESOLD, OR STORED FOR SUBSEQUENT USE FOR ANY SUCH PURPOSE, IN WHOLE OR IN PART, IN ANY FORM OR MANNER OR BY ANY MEANS WHATSOEVER, BY ANY PERSON WITHOUT MOODY'S PRIOR WRITTEN CONSENT. All information contained herein is obtained by MOODY'S from sources believed by it to be accurate and reliable. Because of the possibility of human or mechanical error as well as other factors, however, all information contained herein is provided "AS IS" without warranty of any kind. Under no circumstances shall MOODY'S have any liability to any person or entity for (a) any loss or damage in whole or in part caused by, resulting from, or relating to, any error (negligent or otherwise) or other circumstance or contingency within or outside the control of MOODY'S or any of its directors, officers, employees or agents in connection with the procurement, collection, compilation, analysis, interpretation, communication, publication or delivery of any such information, or (b) any direct, indirect, special, consequential, compensatory or incidental damages whatsoever (including without limitation, lost profits), even if MOODY'S is advised in advance of the possibility of such damages, resulting from the use of or inability to use, any such information. The ratings, financial reporting analysis, projections, and other observations, if any, constituting part of the information contained herein are, and must be construed solely as, statements of opinion and not statements of fact or recommendations to purchase, sell or hold any securities. Each user of the information contained herein must make its own study and evaluation of each security it may consider purchasing, holding or selling. NO WARRANTY, EXPRESS OR IMPLIED, AS TO THE ACCURACY, TIMELINESS, COMPLETENESS, MERCHANTABILITY OR FITNESS FOR ANY PARTICULAR PURPOSE OF ANY SUCH RATING OR OTHER OPINION OR INFORMATION IS GIVEN OR MADE BY MOODY'S IN ANY FORM OR MANNER WHATSOEVER. 75

76 EXHIBIT SRW-4 PAGE 3 of 3 MIS, a wholly-owned credit rating agency subsidiary of MOODY'S Corporation ("MCO"), hereby discloses that most issuers of debt securities (including corporate and municipal bonds, debentures, notes and commercial paper) and preferred stock rated by MIS have, prior to assignment of any rating, agreed to pay to MIS for appraisal and rating services rendered by it fees ranging from $1,500 to approximately $2,500,000. MCO and MIS also maintain policies and procedures to address the independence of MIS's ratings and rating processes. Information regarding certain affiliations that may exist between directors of MCO and rated entities, and between entities who hold ratings from MIS and have also publicly reported to the SEC an ownership interest in MCO of more than 5%, is posted annually at under the heading "Shareholder Relations - Corporate Governance - Director and Shareholder Affiliation Policy." Any publication into Australia of this Document is by MOODY'S affiliate MOODY'S Investors Service Pty Limited ABN , which holds Australian Financial Services License no This document is intended to be provided only to wholesale clients (within the meaning of section 761G of the Corporations Act 2001). By continuing to access this Document from within Australia, you represent to MOODY'S and its affiliates that you are, or are accessing the Document as a representative of, a wholesale client and that neither you nor the entity you represent will directly or indirectly disseminate this Document or its contents to retail clients (within the meaning of section 761G of the Corporations Act 2001). 76

77 PUC DOCKET NO. BEFORE THE PUBLIC UTILITY COMMISSION OF TEXAS TEXAS-NEW MEXICO POWER COMPANY REQUEST FOR APPROVAL OF AN ADVANCE METERING SYSTEM (AMS) DEPLOYMENT AND AMS SURCHARGE PREPARED DIRECT TESTIMONY AND EXHIBITS OF GARY L. KESSLER ON BEHALF OF TEXAS-NEW MEXICO POWER COMPANY 77

78 DIRECT TESTIMONY OF GARY L. KESSLER TABLE OF CONTENTS I. INTRODUCTION AND QUALIFICATIONS... 1 II. PURPOSE OF TESTIMONY... 2 III. ADVANCED METERING SYSTEM & STATEMENT OF FUNCTIONALITY... 2 IV. COMMUNICATION TECHNOLOGY V. VENDOR SELECTION VI. ADVANCED METER CAPABILITIES VII. BACK-OFFICE SYSTEMS VIII. CONCLUSION EXHIBIT GLK-1 GE I-210+C SINGLE PHASE METER SPECIFICATIONS EXHIBIT GLK -2 GE I210+C ELECTRONIC METER PRODUCT DESCRIPTION, OPERATING INSTRUCTIONS, MAINTENANCE INSTRUCTIONS, UPGRADING. EXHIBIT GLK-3 FILED HIGHLY CONFIDENTIAL AND HIGHLY SENSITIVE GE WARRANTY EXHIBIT GLK-4 AMS COMMUNICATIONS NON-COVERAGE AREAS EXHIBIT GLK-5 AT&T DISASTER RECOVERY PLAN 78

79 DIRECT TESTIMONY OF GARY L. KESSLER EXHIBIT GLK-6 AT&T NERC CIP WHITEPAPER EXHIBIT GLK-7 GSMA MOBILE BROADBAND DATA SUMMARY OCTOBER 2009 EXHIBIT GLK-8 SMARTSYNCH CASE STUDIES EXHIBIT GLK-9 DEPLOYING AMI SOLUTIONS- AB EST PRACTICES APPROACH EXHIBIT GLK-10 FILED HIGHLY CONFIDENTIAL AND HIGHLY SENSITIVE KV2C METER DOCUMENTATION EXHIBIT GLK-11 FILED HIGHLY CONFIDENTIAL AND HIGHLY SENSITIVE I210+C RD ELECTRICITY METER REPORT OF TESTS CONDUCTED 79

80 DIRECT TESTIMONY OF GARY L. KESSLER I. INTRODUCTION AND QUALIFICATIONS Q. PLEASE STATE YOUR NAME, BUSINESS ADDRESS, AND PLACE OF EMPLOYMENT. A. My name is Gary L. Kessler, and I am employed by PNMR Services Company ( PNMR Services ), a wholly owned subsidiary of PNM Resources, Inc. ( PNM Resources ). My business address is 225 E. John Carpenter Freeway, Irving, Texas Q. ON WHOSE BEHALF ARE YOU TESTIFYING? A. I am testifying on behalf of Texas-New Mexico Power Company ( TNMP or Company ). Q. PLEASE DESCRIBE YOUR EDUCATIONAL BACKGROUND AND PROFESSIONAL EXPERIENCE. A. I hold a Bachelor of Science in Electrical Engineering from the University of Washington. I have been employed at PNMR Services as the Domain Architect for Smart Grid since March From 2007 to 2009, I held the position of Director of Operations Technology, working for PNM Resources. From 2001 to 2007, I held the position of Director of Technology and Operations for Avistar, a wholly-owned subsidiary of PNM Resources that developed technologies to enhance utility operations. During my employment at Avistar, I was responsible for identifying and developing technologies that aligned with key business strategies and resulted in revenue-generating products for the company. Prior to my employment at PNM Resources, I was the Group Director of Product Development and Operations for Advanced Visual Systems from 1999 to I managed development of strategic products, services and technology roadmap for the company. From 1995 to 1999, I worked for AT&T Wireless Services as a Director of Engineering and Deployment. In this position, I was responsible implementation of third generation and Advanced Cellular Services and technologies into AT&T Wireless cellular network. Prior to my experience at AT&T, I spent 13 years as a Regional Program Manager at Digital Equipment Corporation. I was responsible for marketing, development and implementation of comprehensive service programs and tools for Fortune 500 clients. Additionally, I have also been employed as a Group Program Manager for Silicon Graphics and Senior Engineer at Boeing Company. 1 80

81 DIRECT TESTIMONY OF GARY L. KESSLER Q. HAVE YOU PREVIOUSLY TESTIFIED BEFORE THE PUBLIC UTILITY COMMISSION OF TEXAS OR BEFORE ANY OTHER REGULATORY BODY? A. Yes. I provided testimony in TNMP s most recent rate case, Docket No Q. WHAT ARE THE PRIMARY RESPONSIBILITIES OF YOUR CURRENT POSITION? A. As a Domain Architect for Smart Grid at PNMR Services Company, I am responsible for the development of the Advanced Metering Systems (AMS) program for Texas New Mexico Power Company (TNMP), a PNM Resources ( PNMR ) subsidiary. My responsibilities in this capacity include managing business cases for new technology proposals, developing new AMS technology architecture, assisting with technology development-related regulatory compliance and filings, evaluating and recommending vendors, and facilitating operations support and training in the implementation of AMS for TNMP. Q. HAVE YOU PREPARED ANY EXHIBITS? A. Yes. I have included several diagrams on the technical architecture, function, usage and security of the selected AMS technology. 16 II. PURPOSE OF TESTIMONY Q. WHAT IS THE PURPOSE OF YOUR TESTIMONY IN THIS PROCEEDING? A. I am testifying as the technical representative on the architecture, functionality and security of the AMS system created by TNMP and the selected vendors. 20 III. ADVANCED METERING SYSTEM & STATEMENT OF FUNCTIONALITY Q. WHAT ARE THE SIGNIFICANT COMPONENTS OF TNMP S AMS? A. The components that are essential to the functioning of TNMP s AMS, in accordance to the Commission s rule , are as follows: Meter Data Management System (MDMS) Transaction Management System (TMS) Outage Management System (OMS) AMS Meters 2 81

82 DIRECT TESTIMONY OF GARY L. KESSLER AT&T Cellular Network Q. CAN YOU SUMMARIZE THE FUNCTIONS OF EACH OF TNMP S AMS COMPONENTS MENTIONED ABOVE? A. Yes. 1. Meter Data Management System (MDMS) this component provides the core functionality for support of all business transactions pertaining to metering, metering logistics, and data associated with reading the meter. The MDMS ties together the Meter data and customer business transactions. The MDMS is the Database of Record for all TNMP meter data, meter transactions pertaining to customer activity, and meter logistics as it relates to change outs, meter type, serial number, and other requirements necessary to meet all components of and the AMIT business use cases. See my testimony regarding the MDMS for further discussion. 2. Transaction Management System (TMS) TMS is the head end data collection and meter communication system. It is responsible for collecting all meter data, routing alarms, and performing meter specific actions as dictated by the MDMS. TMS also performs network management, firmware updates, and meter health checks on a routine basis. TNMP plans to outsource to SmartSynch the operation and management of TMS. At the end of the deployment, TNMP will evaluate the cost benefit option of continuing to outsource this functionality versus procuring TMS and moving the functionality in-house. The AT&T cellular network will then communicate directly with TNMP s back-office systems and use all of TNMP s security processes. 3. Outage Management System (OMS) the OMS responds to meter outage messages and all alarms generated by the meters and processed by TMS. Generally, it is the responsibility of the OMS to manage all alarms generated by TMS. Specifically, the OMS will generate high-priority alarms for tampering events and outage events. Each event will create an actionable item in TNMP s work management system that causes intervention by a TNMP employee. 4. AMS Meters These meters read consumer electric energy usage and pass it to the TMS system on request. The meters also perform remote connects and 3 82

83 DIRECT TESTIMONY OF GARY L. KESSLER disconnects, generate alarms based on events that transpire on the electric system such as outage notifications, tamper events, and other significant alerts. 5. AT&T Cellular Network this is the communications backbone of the TNMP AMS network. The AT&T cellular network carries all the data to and from TNMP s deployed meters, providing an IP-based two-way communications link. For the TNMP network, this replaces the expensive, private networks that are generally built for AMS deployments. The data portion of the network, which will be used by the TNMP AMS system, is highly secure and extremely reliable, as described in the security portion of my testimony. I will describe the network in more detail later in my testimony. Q. WHAT COMMUNICATION TECHNOLOGIES IS TNMP PLANNING TO USE IN ITS DEPLOYMENT OF ADVANCED METERS? A. In an effort to provide the most cost effective, secure, and reliable AMS network to its consumers and customers, TNMP has chosen to utilize existing cellular public networks as the AMS network. TNMP has a widely distributed, non-contiguous service territory encompassing West Texas, Central Texas, North Texas and areas of East Texas. With this service territory, it is a prohibitively expensive solution to build-out a private network, either wireless or wired, to cover TNMP s service geography. The TNMP service territory is approximately 10,000 square miles with about 230,000 customers. That is approximately an average of 23 meters/ square mile, versus other Texas investor-owned utilities that range in meter density from approximately 10 to 400 meters per square mile (Centerpoint = 5,000 sq miles/2m meters; Oncor = 27,000 sq miles/3.4m meters; TNMP = 10,000 sq miles/230k meters; AEP Texas= 97,000/1M meters). The majority of TNMP s AMS deployment will use the AT&T cellular network as the carrier of choice. AT&T has cellular coverage to the majority of TNMP s existing meter locations based on a geo-coded comparison with AT&T s existing coverage maps. For those customers who reside outside the current AT&T coverage areas, there are alternatives which have been identified by TNMP. During the course of the deployment, AT&T may expand their coverage to encompass some of these areas. A second consideration could be entering an agreement with an alternative carrier, such as Verizon, T-Mobile or Sprint. In the event that AT&T, or another carrier, is unable to provide service to these customers, TNMP will review alternative technologies, such as 4 83

84 DIRECT TESTIMONY OF GARY L. KESSLER satellite, Power Line Carrier, Wi-MAX, or private network, attempting to find a cost effective solution to provide AMS to those customers who fall in the deficient coverage area. TNMP will make its best effort to provide AMS to all the customers within its service territory using cost effective technology solutions. The cellular tower to meter communications technology will utilize General Packet Radio Service (GPRS). General Packet Radio Services (GPRS) is a packet-based wireless communication service that provides data rates from 56 up to 114 Kbps and continuous connection to the Internet for mobile phone, computer users, and meters. GSM Association (GSMA - leading industry association for GSM) represents that GSM/GPRS is currently the largest cellular technology in use around the world, used in over 860 networks in more than 220 countries. Further information can be viewed at or in the attached document from GSMA that provides an inventory of existing and proposed GSMA networks worldwide. The following diagram illustrates TNMP s wireless architecture that is proposed for this AMS filing. Figure GK 1 - TNMP Communications Network Q. PLEASE DESCRIBE TNMP S PROPOSED AMS. 5 84

85 DIRECT TESTIMONY OF GARY L. KESSLER A. TNMP s proposed AMS includes advanced meters, the associated computer hardware, testing and meter programming systems, server and applications software, public and private communications networks, and the back-office systems that will collect and provide time-differentiated energy usage to customers and their REPs through the Smart Meter Texas web portal described later in this testimony. The proposed AMS system is illustrated in two diagrams. Figure GK 1 illustrates the proposed communication architecture which will communicate with all deployed Smart Meters and will pass meter data, alarms, and information to SmartSynch s TMS system, and then to TNMP s Meter Data Management System. Figure GK 2, below, depicts the required back-office systems that will be implemented or modified as part of this filing. For the sake of clarity, the acronyms used in the diagram are defined as follows: CIS=Customer Information System; OMS = Outage Management System*; WMS=Work Management System; GIS=Geographic Information System; IVR=Interactive Voice Response Unit; Interval Billing=Interval Billing System*; Service Suite=In-Truck Dispatch; Meter Data Archive=AMS Meter data repository*; MDMS=Meter Data Management System*; TMS=Transaction Management System (Head-End Meter Reading)* Figure GK 2 - AMS Back-office systems

86 DIRECT TESTIMONY OF GARY L. KESSLER Q. CAN YOU DESCRIBE THE EVOLUTION OF THE ADVANCED METER TECHNOLOGY TESTED AND USED BY TNMP? A. TNMP has been conducting technology trials over the past three years of various meter and technology configurations. More specifics of the trials can be found in Mr. Burke s direct testimony. In December of 2007, TNMP installed 100 cellular based Elster A3 meters in the Clifton service territory. The Elster A3 meters do not have remote disconnect/reconnect as part of the configuration, as this feature was not available at the time of the trial. TNMP chose to dual meter 10% of the installations, using the old meter/new meter over a 3-month sample period. Results of the dual meter sample showed no difference in meter readings. These dual meter installations are still in place in the Clifton service territory. In June of 2008, TNMP initiated a larger trial of meters using a hybrid technology of cellular network to a collector and Power Line Carrier (PLC) from the collector to the meter. The vendor, Echelon, provided AMS meters that had a remote disconnect switch which allowed TNMP to test the impact of remote service activation and de-activation. TNMP installed these meters in the Lewisville and Gulf Coast service territories, largely on high density occupancy buildings. After a year and a half trial, TNMP reviewed the results and determined that, although the meters performed accurately and allowed for reliable service activation and deactivation, the vendor would not meet the TX HAN requirements, and bandwidth to the meter was significantly limited such that market requirements for real-time meter reads may exceed the systems capabilities. No further installations were scheduled. In May of 2009, TNMP began a larger trial of cellular-based meters that fully complied with Substantive Rule requirements. These meters have been deployed in various locations in the TNMP service territory; specific locations can be found in Mr. Burke s direct testimony. TNMP has replaced all previous trial meters with this current technology. The results of the trial have been very successful. Key functionality tested with this technology has been: remote firmware upgrades, tampering alarms, remote service activation and deactivation (connect/disconnect), 15-minute data collection, twoway communication, and real-time meter pings. TNMP has not tested HAN messaging yet, but will test that functionality once AMIT market requirements and use cases are 7 86

87 DIRECT TESTIMONY OF GARY L. KESSLER fully completed. The meters exhibit an extremely reliable communications history (99.9%) and are very consistent in the success of first-time read requests. Q. WHAT AMS TECHNOLOGIES IS TNMP PLANNING TO USE IN THE DEPLOYMENT OF ADVANCED METERS? A. Based on the results of the AMS meter trial, TNMP will use the GE-I210+c cellular based meter as the AMS solution for single phase residential and commercial installations. This meter is a multi-function residential meter that uses a vendor specific communications module plugged into the meter under the glass. A detailed description of the meter functionality and accuracy can be found in the attached exhibits 1. An important distinction to make regarding this technology is that SmartSynch provides only the communications module, integrated into the GE meter. The Smart Synch module does NOT have any embedded meter functionality or metrology on the communications board, unlike other vendor solutions. All meter data is collected by the meter and stored in the GE meter on the register board. This avoids duplication of functionality and potential for meter data errors to occur. For non-idr installations and poly-phase residential customers, TNMP will utilize the GE kv2c industrial meter. This meter meets and exceeds all PUCT requirements for AMS functionality, with the exception of a remote disconnect. The market currently does not support technology for remote disconnect, under glass, for poly-phase meters over 200 amps. I discuss this later in my testimony. Key features provided by the GE kv2c meter are: Revenue Accuracy (with DC Detection capability) Installation Verification and Tamper Detection Tools Coincident Demand Measures Power Quality Monitoring and Analysis AMR System Integration Options 20 Channel Recording Totalization Options (with 4 external inputs) 4-Quadrant Industrial or Substation Measures 1 Exhibit GLK-1 through Exhibit GLK

88 DIRECT TESTIMONY OF GARY L. KESSLER Per Phase AC Instrumentation (amps, volts, and frequency) An expanded description of the GE kv2c 2 meter functionality can be found in the exhibits 3 attached to my testimony. For the purpose of this testimony, I will focus on the GE I210+c meter, as that meter technology will be the pervasive technology installed for this project. The SmartSynch communications module will support upgrading the meter communications firmware to support the ANSI C12.22 standard. This can be done over-the-air, where the firmware is upgraded remotely. The SmartSynch communications module also has the ability to perform over-the-air upgrades of the communications firmware and HAN communications protocols. The GE I210+c meter is used by multiple AMI vendors as part of their AMS solutions. As such, the GE I210+c is a highly reliable meter 4 with a calculated Mean-Time-Between failure of greater than 50 years. TNMP reserves the right to deploy more than one meter vendor as long as the meter meets all requirements of Substantive Rule (g) and is cost equivalent. The GE I210+c meter is a widely utilized meter in the industry. Table GK-1 below is a short list of utilities deploying the GE I210 family meter: Table GK 1 - US GE I210 Meter deployments Utility Communications Network Meter Type Approx. Endpoints AEP RF System I-210+c / kv2c OG&E RF System I-210+c / kv2c PHI RF System I-210+c / kv2c Installed > 2M one way meters and >120k units (Pilot System 2way) >800k units >1Million units 2 Highly Confidential and Highly Sensitive Exhibit GLK-10 3 Exhibit GLK-1 through Exhibit GLK-3 4 Highly Confidential and Highly Sensitive Exhibit GLK

89 DIRECT TESTIMONY OF GARY L. KESSLER Florida Power & Light Pacific Gas & Electric RF System I-210+ >4Million units RF System I-210+/kV2c >4Million units Misc REC Utilities PLC System I-210 / I- 210+/kv2c >1Million units The GE I210+c uses a daughter card configuration for plug-in communications and networking modules. It is used by many other AMI providers, most notably Silver Spring Networks, Sensus and Trilliant, as noted by GE. The GE I210+c meters are deployed at several utilities, using different communications technologies to achieve a functional AMI solution. Q. DO THE ADVANCED METERS SELECTED BY THE COMPANIES MEET THE TECHNOLOGICAL REQUIREMENTS OF SUBST. R (G)? A. Yes, the advanced meters to be deployed by TNMP, pursuant to the AMS Deployment Plan described by Mr. Whitehurst in his direct testimony, provide the capabilities to comply with all AMS requirements outlined in Substantive Rule (g). The table below compares the meters proposed to be installed by TNMP to the minimum advanced meter functionalities set forth in Substantive Rule (g)(1)(a-k). Q. WILL TNMP S AMS ALLOW AUTOMATED OR REMOTE METER READING? A. Yes. As described above, and in the testimony of Mr. Whitehurst, the TNMP AMS meets all technical AMS requirements defined in Substantive Rule (g). The AT&T network provides highly reliable communications to the meter (as exhibited in the TNMP AMS meter trial where meter availability is often at 99.9%). During the TNMP trial, the AT&T cellular network has consistently provided repeatable communications with the deployed AMS trial meters. The details of the TNMP AMS meter trial are described in the direct testimony of Mr. Burke. Q. WILL TNMP S AMS ALLOW TWO-WAY COMMUNICATIONS? A. Yes. The AT&T cellular communications network will provide for two-way communications and alarm signaling from the deployed AMS meter. The GE-I210+c 10 89

90 DIRECT TESTIMONY OF GARY L. KESSLER meters employ a push or pull technology for alarms and meter data. Meters can be programmed to push meter data at a specified time to the head-end system, or they can be read in a polled manner by the head-end system. Meter alarms are all pushed immediately to the head-end system. The GE I210+c communications board utilizes a super cap technology which allows the meter to provide a real-time outage and tamper alarms to the outage management system 1-2 minutes after power loss. The meter does NOT use batteries to power alarms. Lithium Ion (Li-On) Batteries are used as a backup power source for timekeeping whenever the meter experiences a power outage. Figure GK 3- SmartSynch Comm Board Using GPRS technology will provide a larger bandwidth pipe directly to the meter than most industry wide AMS solutions. As mentioned earlier in my testimony, General Packet Radio Services (GPRS) is a packet-based wireless communication service that provides data rates from 56 up to 114 Kbps, thus ensuring timely reading and reporting of meter data, bandwidth for future applications, and reliable communications. This bandwidth is on a per meter basis, as there are no collectors to diminish bandwidth in the TNMP AMS architecture, and few points of failure in the network. Q. WILL TNMP S AMS ALLOW REMOTE DISCONNECTION AND RECONNECTION? 11 90

91 DIRECT TESTIMONY OF GARY L. KESSLER A. Yes. This function is currently being used in production as part of the AMS meter pilot. Disconnects and reconnects are generally completed within 5 minutes of a request being issued by the operator. The disconnect mechanism is rated at 200 amps and is under glass on the GE I210+c meter. Q. WILL TNMP S AMS HAVE THE CAPABILITY TO TIME-STAMP METER DATA? A. Yes. All meter data is time-stamped using a Greenwich Mean Time (GMT) format when read. When expressed in terms of a 24-hour clock, GMT is also called universal time (UT or Z). It is five hours ahead of the US Eastern Standard Time (EST), during standard period, and four hours ahead during the US daylight-saving period. Q. WILL TNMP S AMS HAVE THE CAPABILITY TO PROVIDE CUSTOMER USAGE DATA? A. Yes. This functionality is available to external customers via the Smart Meter Texas (SMT) Web Portal project. Meter data will be stored in TNMP s MDMS after being properly validated in accordance with market rules in place. The data will then be pushed to the Smart Meter Texas ( SMT ) Web Portal within the required time window as defined by the emerging AMS market rules Q. WILL TNMP S AMS PROVIDE A MEANS BY WHICH REPS CAN PROVIDE PRICE SIGNALS AND COMMUNICATE WITH DEVICES INSIDE THE HOME? A. Yes. TNMP s AMS architecture will communicate to the Smart Meter Texas Web Portal to accept price signals and messages, and then pass those messages to the meter s ZigBee communications device for transport into the home. Status will be returned to the TNMP MDMS which will record the transaction status and pass it for posting on the Web Portal. An important point to note, in compliance to the new business requirements being developed by AMIT and as documented in the AMIT use cases, the status that is reported to the Web Portal is the success or failure of the transport of the message packet to the meter HAN interface, NOT if the message actually made it to the end device in the home, as currently defined AMIT use cases. The SMT portal will interface with TNMP s MDMS which will respond to request from the SMT. Q. WILL TNMP S AMS HAVE THE CAPABILITY TO PROVIDE 15-MINUTE DATA? A. Yes. TNMP s AMS pilot is currently capturing 15-minute data at the meter and returning it to the Transaction Management System, hosted by SmartSynch. TNMP cannot 12 91

92 DIRECT TESTIMONY OF GARY L. KESSLER actively utilize the 15-minute data from the meter until the implementation of the TNMP MDMS and back-office systems. Q. WILL TNMP S AMS BE CAPABLE OF ON-BOARD METER STORAGE OF METER DATA? A. Yes. The GE I210+c meters can hold 85 days of two channel, 15-minute interval data. The meter will hold 170 days of one channel, 15-minute data. Q. WILL TNMP S ADVANCED METERS HAVE OPEN STANDARDS AND PROTOCOLS? A. Yes. The entire TNMP AMS architecture is based on open standards and emerging National Institute of Standards and Technology (NIST) recommended protocols. The communications protocol is TCP/IP from back-office to the meter. The GE I210+c meter utilizes ZigBee SE 1.0 for the Home Area Network (HAN). It is firmware programmable to ZigBee SE 2.0 and will support any protocol. The meter communications to the head-end system will be C The C12.22 protocol will be implemented once the firmware update becomes available from SmartSynch. Q. WILL THE AMS HAVE THE CAPABILITY TO UPGRADE THE ADVANCED METERS AS TECHNOLOGY ADVANCES? A. Yes. Of primary concern to TNMP is the advance of communications technology and ability to conform to changing or new standards. As requirements change, and communications technologies advance and/or retire, the GE I210+c meter is modularly upgradable. The SmartSynch communications hardware and firmware is built on a single daughter board. The board is inserted into the meter cage and provides all communications (cellular and ZigBee) for the meter. Retrofitting a new board to the meter is a simple process with this technology and is completed by a simple swap out the old communications board. The following figure shows the installation location of the SmartSynch communications module. The module is installed as a snap-in under the meter faceplate board. This makes for a simple process to replace the existing communications board with a new or upgraded technology communications board. Figure GK 4-GE Meter w/ Module installed 13 92

93 DIRECT TESTIMONY OF GARY L. KESSLER 1 2 IV. COMMUNICATION TECHNOLOGY Q. PLEASE DESCRIBE THE COMMUNICATIONS TECHNOLOGY SELECTED BY TNMP FOR ITS AMS? A. As discussed in greater detail earlier in this testimony, the majority of TNMP s AMS deployments will use the AT&T cellular network as the carrier of choice. AT&T has coverage to the vast majority of the existing meter locations, based on a geo-coded comparison with current AT&T coverage maps as provided by AT&T. Those locations in the TNMP service territory are called out in an exhibit 5 attached to this testimony. Q. HOW DOES THIS COMMUNICATION TECHNOLOGY WORK? A. These meters function like a cell phone browsing the internet or downloading an application from the itunes or the online Blackberry store. Each deployed meter has a GPRS radio embedded under the glass. The GPRS radio functions as a data modem and connects to the nearest AT&T cellular tower. The connection between the tower and the meter is only active on an as-needed basis. When a customer, or a REP, 5 Exhibit GLK-4, GLK

94 DIRECT TESTIMONY OF GARY L. KESSLER makes a request to read the meter registers, the data flows from the web-portal, to the TNMP MDMS where the transaction is recorded and processed according to the business rules of the market. The appropriate data is then forwarded to TMS from the MDMS. TMS then passes data, using secure transactions, by communicating with AT&T servers. AT&T s cellular network then signals the meter to wake-up and the data is transmitted to the meter over the cellular air-link. Meter data is returned using the same pathway. Q. WILL YOU DESCRIBE THE DATA SECURITY FEATURES OF TNMP S PROPOSED AMS IN DETAIL? A. Yes. I will address the data security by security domains as illustrated in Figure GK 4. AMS Security (Communication and Application) AMS security is tiered in three levels across four security domains. The levels are device, application, and network. The four security domains are: the device, the airlink, network connectivity, and enterprise connectivity. The following exhibit shows the security standards in use for each of the four security domains, and at what tier they are utilized in the network: 15 94

95 DIRECT TESTIMONY OF GARY L. KESSLER 1 Figure GK 4 - Security architecture Device: GE I210+c Meter Security The meter devices employ the message security methods described above. If a device receives a message that does not meet all of the accepted criteria for compression, encryption, etc., that device will send a notification message to TMS that it has received an invalid message. Meter passwords are set up when the meter is initially configured. This configuration establishes ownership of each device with TMS by loading appropriate encryption keys and reporting addresses. Once the GE I210+c meter is deployed, users can access it in one of three ways: Via the optical port using manufacturer-provided software (such as MeterCat or PC Pro). User authentication and level are verified by this software. Via the optical port using SmartSynch s Stamp software. A user name and password are required to log on to the software. In addition, all communications 16 95

96 DIRECT TESTIMONY OF GARY L. KESSLER between Stamp and the GE I210+c SmartSynch communications module are encrypted using the utility s encryption key (assigned during integration). Wirelessly from TMS. All communications between TMS and the GE I210+c are encrypted using a meter-specific key derived from the utility s encryption key and the meter s serial number. All other communications are rejected and messages received by the GE I210+c are considered spam. The meter notifies TMS if repeated spam messages are received. All messages from foreign devices are logged. Air-link Security: Message Payload All messages transmitted across the network are encrypted using keys that are built from multiple key seeds. Encryption requires three unique keys, which provide meterspecific encryption. One key is unique to SmartSynch, one key is unique to the utility, and the other is unique to the meter. The meter has to pass three authentication challenges from the network and then attaches to a VPN tunnel created specifically for TNMP s Access Point Name (APN), which is the AT&T designated private network that TNMP will utilize to communicate data to and from the meter to the back-office. Many carriers base their billing plans on the amount of data transmitted. To optimize data transfer and reduce cost, significant compression and redundant data elimination is performed on each message. Meter data that does not contain information of value may be eliminated from the payloads transmitted across the network. Indicators are used in the message to indicate where zero or blank data was eliminated. In addition, messages are converted to a binary format where appropriate to reduce message size. The AMS utilizes AES-256 encryption for all data transmissions. Each message that leaves TMS is subjected to the processes of data elimination, binary conversion, compression, and encryption. There are security measures in place to ensure that intercepting data from the cellular network and meter is extremely difficult. But the core of the security methodology employed is for SmartSynch s technology designed to keep data thieves from being able to successfully translate or interpret any data that they may steal (which is the same concept used for all Internet credit card transactions using SSL encryption). To steal meaningful data from the AMS, a data thief would need to complete all of the following: 17 96

97 DIRECT TESTIMONY OF GARY L. KESSLER Determine/Utilize a specialized device for sniffing packets on the network and ensure the device can authenticate as a valid base station with the network. Steal/Determine the meter-specific portion of the encryption key Steal/Determine the utility-specific portion of the encryption key Steal/Determine the SmartSynch portion of the encryption key Steal/Determine the encryption algorithm that SmartSynch utilizes Decrypt the payload Steal/Determine the compression algorithm that SmartSynch utilizes Decompress the payload Convert the payload from binary to hex ASCII Determine/Steal SmartSynch s transport format Decode the transport payload Determine/Steal SmartSynch s command format Decode the command payload Break into the utility s TMS database and steal a relevant account number/tms device ID mapping Break into the utility s billing system to match a stolen account number with a customer name in order to determine whose data had been stolen. To date, theft of data from a SmartSynch meter in this manner (or any other manner) has never been accomplished. IF a data thief successfully performed these actions (which would be extremely difficult), there would be no guarantee that the stolen data actually would represent the intended customer or customers data, or even that the stolen data would represent complete packetized messages (after intercepting data, a thief looking at a bit stream would have no way of knowing where the messages and packets within each message begin and end). Although it is technically possible to execute all the above steps, it has never been done to date, and such a process would be very time consuming, requires extensive technical knowledge and carrier proprietary communications equipment, and is extremely costly

98 DIRECT TESTIMONY OF GARY L. KESSLER Air-link Security: TMS to GPRS Meter Devices Each GPRS device connects via IP to the TMS system. For the GE I210+c meters using the GPRS network, the System adds another communications server to manage IP connections with large numbers of devices. A device with information to report will connect to the IP address of the communications server. This connection will be authenticated by the communications server to verify that the requesting device is a valid meter. The communications server not only authenticates the devices but also verifies and uses only the protocol defined and implemented in the SmartSynch communications module. Once the connection is authenticated, the communications will occur in the same encrypted manner as all other device communications. The communications server may reside on the same computer as TMS or may be placed on a separate machine. The communications server will typically reside either outside the utility s network or in the network Demilitarized Zone (DMZ). To further enhance security, the utility s firewall would be configured to allow connections within valid IP and port ranges only, or other secure connectivity methodology as identified by PNMR s security organization. Application Security TMS is a browser-based system used to manage devices and data. The system incorporates the following security mechanisms: Authentication. Users are first authenticated as valid users of the system. An administrator must create users in the system. Each user is created with both a profile and a password. These items are stored in an encrypted format in the TMS database. If a profile is repeatedly attempted with invalid passwords, that profile will be disabled and the administrator will be notified. This prevents automated tools from attempting to determine the password. All invalid account and password access attempts are logged. Authorization. The TMS system operates on a see and do model. In other words, the users can see only the options for which they are authorized within the system. There are four levels of authorization: 19 98

99 DIRECT TESTIMONY OF GARY L. KESSLER Administrators have full access to all activities in the system. This includes all activities of the other users as well as the ability to administer users and system activities such as archiving data. 2. Operators can perform operations on devices. This includes the abilities to add, change, and delete devices and schedules. Most of the modifications to device configuration include the execution of commands over the air to the devices. 3. Analysts can run reports and exports in the system as well as view the monitoring functions. Analysts cannot send commands to devices. 4. Contacts are not actual users of the system and cannot log in. They can receive notification of certain events. Device Verification. TMS is aware of those devices that should be reporting to it. If a message is received from a device outside of those registered, a message is logged as an alien message. Enterprise Network Security: TNMP connectivity to SmartSynch s TMS & AT&T s Servers The enterprise communications path for TNMP s AMS will be from the Smart Meter Texas portal to TNMP s back-office system (specifically the Meter Data Management System) which communicates to SmartSynch s TMS system. TMS sends and receives data from the AT&T servers which manage the AT&T cellular network. Messages sent to meters utilize a mailbox on the AT&T Server. The TMS system initiates a TCP/IP socket connection from inside the utility s firewall out to the AT&T Server in order to open the mailbox with an ID and password. TMS then polls the mailbox on the AT&T Server to see if any messages are available. Any messages are passed through the socket connection to TMS, which securely relays the data back to TNMP s MDMS. Security Summary The TNMP AMS utilizes several layers of distributed security to minimize the potential of unauthorized access to meter data. In addition, none of the messages actually provide identifying information of a device. Therefore, without access to a utility s billing system, there is no way to link a message to a particular customer

100 DIRECT TESTIMONY OF GARY L. KESSLER Decommissioning The most important cyber security risk is the unintended release of sensitive non-public data through the careless disposal of media and/or assets. TNMP s parent company PNMR, has an established a Media and Asset Disposal policy which outlines specific requirements that must be met for the secure disposal of PNM Resources media or equipment that contains sensitive non-public information. a) Media or equipment that is known or suspected to contain information that may be associated with current/pending litigation or used in forensic activities must not be destroyed or released from PNM Resources control. b) Media shall be disposed of securely when it is no longer usable, when the information contained on the media has no value, or when there is no legal reason to keep it. c) Systems, network components, and storage media shall be purged of all PNM Resources information before being released from PNM Resources control to third parties for sale, lease return, donation, or salvage. Information on the magnetic media shall be rendered unrecognizable (purged/sanitized) prior to release. d) In the event that PNM Resources cannot perform the required purging prior to the media being released from PNM Resources control, agreements must be in place with the receiving third party to perform and certify the required destruction. e) If the media is not destined for maintenance, reuse, or salvage, it may be destroyed in lieu of being purged. f) Under no circumstances shall deleting files or formatting the drive be considered an acceptable form of rendering magnetic media unrecoverable. Security Inspection(s) or Audits Security of TNMP s AMS infrastructure will be audited using both PNMR s internal and third-party security resources. Audits of security configurations and activity logs will be performed on several levels. Controls for review of access and alert logs will be maintained, and internal audits of these activities will be performed regularly. In addition, bi-annual third party audits of controls will also be conducted in accordance with current security practices. All audits will be conducted in accordance with

101 DIRECT TESTIMONY OF GARY L. KESSLER published industry standards including those of NIST Computer Security Division, ISO/IEC & 27002, and NERC CIP Q. PLEASE SUMMARIZE WHY THE SELECTED COMMUNICATIONS TECHNOLOGY WILL WORK FOR TNMP S SERVICE TERRITORY. A. TNMP s selected technology is not a revolutionary approach to remote meter reading. It s an outgrowth of Moore s Law, where technology becomes available at cheaper prices every months. The technology selected by TNMP has been used in the Commercial and Industrial (C&I) metering space for several years. C&I meters have been deployed and read remotely using Plain Old Telephone Service (POTS). Itron s MV90 product was created specifically for the purpose of reading C&I or Interval meters remotely. SmartSynch has replaced the POTS service with cellular technology and then built hardware that can be inserted into a meter, much like a communications card into a computer. With Cellular Carriers now actively embracing this technology and approach 7, the pricing for using cellular service is now as cost effective as traditional meter reading in urban/suburban areas and much cheaper than traditional meter reading methods in rural areas. This technology is already widely deployed in Europe. Bern Insight, European Analyst firm, projects that by 2014 EU Countries will have installed 10M GPRS based meters. Norway/Finland deployment is expected to add another 10M to that total. The Smart Synch technology is deployed in 120+ clients in North America as listed in Table GK 2. TNMP has been using this technology in the AMS meter trial for 18 months and is achieving a 99.9% first time read success rate. TNMP is currently using all of the AMS meters in the trial as production meters, providing daily 15-minute usage data, connects and disconnects, re-reads, and tamper detection. TNMP s experience is that once installed, these meters can go into production within a couple of hours. This technology requires no network build-out and limited network testing as it uses existing AT&T cellular network technology and footprint. 6 Exhibit GLK-6 7 Exhibit GLK

102 DIRECT TESTIMONY OF GARY L. KESSLER Table GK 2 lists 125 utilities that have deployed all or some portion of a SmartSynch GPRS meter solution within their service territories. In some cases, the deployed solution was for 2-way read of Commercial and Industrial meters, and in other cases utilities deployed a solution for hard-to-reads and remote meters. In all cases, the deployed solution utilizes similar technology and architecture as the proposed TNMP solution. 8 Table GK 2 - Utilities deploying similar AMI solutions 4-County Electric Coop Erie Thames New Hampshire Electric Southern Company : Southern Company Services Ameren Essex Power Services Niagara Falls Hydro Southern Company: Alabama Power American Electric Power (AEP) Exelon (ComEd) Niagara Mohawk Power Corp. (NIMO) Southern Company: Georgia Power Austin Energy Festival Hydro Inc. Niagara on the Lake Hydro Southern Company: Gulf Power Austin International Inc FirstEnergy Niagara Peninsula Southern Company: Mississippi Power Baldwyn County EMC Baltimore Gas and Electric Florida Power & Light (FPL) Fortis Ontario : Cornwall Electric Blue Ridge Electric Coop Fortis Ontario : Westario Power Inc. NSTAR NYSEG Omaha Power Public District Southern Pine EPA Southern Rivers Energy Southwest Mississippi Electric Power Assoc. Canadian Niagra Power Central Florida Electric Coop Georgia Systems Operation Co Gila River Community Utility Authority Orlando Utilities Commission Pacific Gas and Electric (PG&E) St. Thomas SunRun, Inc Central Iowa Power Goderich Hydro PacifiCorp Tampa Electric Co. Choctaw Electric Coop Greystone Power Company Pennsylvania Power & Light (PPL) Tennessee Valley Authority 8 Exhibit GLK

103 DIRECT TESTIMONY OF GARY L. KESSLER Citizens Electric Grimsby Power Inc. Portland General Electric City of Anaheim Haldimand Hydro Potomac Electric Power Corp. (PEPCO) Tillsonburg (Town of) TNMP (AMS trial) City of Griffin Halton Hills Hydro Inc. PowerDash LLC Toronto Hydro Clark County REMC Hydro One PowerStream Trico Electric Cooperative Inc. Clark Public Utilities Hydro Ottawa Progress Energy Tucson Electric Clay Electric Coop Hydro Quebec Public Service Electric and Gas (PSE&G) University of Colorado COBB Energy Collingwood Hydro Connecticut Power & Light Consolidated Edison of NY Imperial Irrigation District Indyne, Inc. (Cape Canaveral Air Force Base) Puget Sound Energy Reliant Energy University of Mississippi University of Mississippi Medical Center Jackson EMC Roseville Electric Utility Specialists, Inc. Jamaica Public Service Salem Electric Veridian Consumers Energy Coop Kitchener-Wilmot Salt River Project Wabash Valley Power Delmarva Lockhart Power San Diego G & E Wasaga Distribution Dominion Los Angeles Department of Water and Power (LADWP) Santee Cooper WE Energies DTE Energy Duke Energy Madison Gas & Electric Memphis Light Gas and Water Sawnee EMC SCANA (SCE&G) Welland Hydro West Perth Energycom Networks MidAmerican Energy SMUD Whitby Hydro Enersource Midland Power Cooperative Snapping Shoals EMC Entergy National Grid Southern California Edison (SCE) Woodstock Hydro Xcel Energy

104 DIRECT TESTIMONY OF GARY L. KESSLER In summary, data over cellular is a proven technology with a high reliability and repeatability factor. The network infrastructure associated with communications of meter data is now maintained and managed by AT&T, a company whose core business is the success and quality of that network. The use of these public networks, run and maintained by large Carriers, allows TNMP to avoid the cost and responsibility of maintaining a private network, and still be allowed to take advantage of AT&T disaster recovery mechanisms 9. TNMP s cost burden for AMS is reduced by not having to bear the maintenance and repair costs for the AMS communications infrastructure or cost of disaster recovery for that infrastructure. As TNMP will use data over cellular to provide transport of meter data, there will be a cellular data plan associated with each GE I210+c installed in the field. The data plan for TNMP will be arranged with AT&T to provide 1 Megabyte (MByte or MB, where one byte = 8 bits) of data transported each month bi-directionally for each meter. TNMP s plan is a bucket plan of 240MB, paid for monthly. TNMP is responsible for overages against the total plan, but not individual meters. TNMP will monitor usage for each individual meter to network performance, bandwidth consumption, and conformance to market rules on pinging the meter. Individual meter overages will be assessed to the offending REP via a new tariff as a method to manage bandwidth and enforce market rules. The GE I210+c meter, using SmartSynch s communications board, is extremely efficient in compression and transmission of data. The meter data uses about 1.1 kilobytes (kbytes or kb) of data for each transmission. A standard transmission is one day s worth of data at 1.1 kb for 96 increments of 15-minute data. A meter ping is also about 1.1 kb of data Q. PLEASE DISCUSS HOW TNMP CAN TAKE ADVANTAGE OF AT&T DISASTER RECOVERY MECHANISMS. 9 Exhibit GLK

105 DIRECT TESTIMONY OF GARY L. KESSLER A. AT&T has a comprehensive and extremely mobile disaster recovery solution. As part of my testimony, I have attached exhibits 10 from AT&T s Disaster Recovery Webinar which provides summary overview of their Disaster Recovery capabilities and some examples of the response to Hurricane Ike and 9/11 in New York City. Functionality of the TNMP AMS network during a disaster event would be compromised to some extent with regard to priority-of-service and possible outage of cell towers, affecting coverage. During a disaster event, as depicted in the attached exhibit 11 from the Webinar, AT&T will roll a large contingent of trucks to an area to re-establish cell coverage in the affected geographies. This is done using mobile cell towers, placed in strategic locations. Satellite service is also utilized for voice and data should there be extensive damage to the cell network. Once emergency service is restored, first responders and public safety will always have first priority in utilization of AT&T disaster resources. However, as a utility customer for AT&T with a private network, the AMS would have access to unused bandwidth during the evenings to collect meter data. As normal service is restored by AT&T, TNMP s AMS would resume normal operations. By utilizing the AT&T network as our communications backbone, TNMP avoids the building and maintenance costs of the infrastructure of a private network dedicated to AMS, as well as the capital and O&M costs of repair during and after a disaster. These factors allow TNMP to lower overall costs during a disaster event and positively affect any ensuing proceeding to recover those AMS repair costs. V. VENDOR SELECTION Q. PLEASE DESCRIBE THE AMS VENDOR SELECTION PROCESS. A. Vendor selection was accomplished via the Request for Proposal (RFP) process issued by PNMR s supply chain organization. An RFP was released to five of the AMS vendors currently doing business in the market. Three vendors responded with questions, and two submitted proposals. The process was managed by PNM Resources Supply Chain organization and supported by TNMP operations, PNMR Regulatory and PNMR 10 Exhibit GLK-5 11 Exhibit GLK

106 DIRECT TESTIMONY OF GARY L. KESSLER Business Technical Services groups. Proposals were evaluated on requirement conformance, technical merit, and submitted costs. Q. WHAT WAS THE OBJECTIVE OF THE REQUEST FOR PROPOSAL? A. The purpose of the proposal was to acquire a solution that meets the requirements of Substantive Rule and could be implemented to meet all AMIT market use cases. In addition, TNMP wanted an AMS solution that would provide long term functionality without the burden of maintenance and management of AMS communications infrastructure, and which would provide a cost effective solution for rural and remote areas of the service territory. As TNMP is a highly capital constrained utility, effective use of O&M monies and Capital is of priority concern to management. Core business drivers for this solution were, and still are: Meet all requirements outlined in PUCT Substantive Rule Meet all requirements generated by the PUCT AMIT meetings. Avoid building, designing, and maintaining a private network. A wireless network is preferred, with no or few Utility owned or operated assets. Wherever possible, use of utility or public network assets is preferred, preferably IP based. Avoid the use of public frequencies for reasons of security, bandwidth, and future spectrum clearing. Minimize network costs; ensure optimal use of network bandwidth for meter data Simple installation Plug & Play hardware. Flexible solution options. Modularized technology approach to minimize stranded assets and future-proof investment. Support of multiple meter vendors; no single source. Secure and reliable transactions; repeatable and measureable 99% first time read success. In-field meter and network diagnostic capabilities for troubleshooting

107 DIRECT TESTIMONY OF GARY L. KESSLER Communications framework that will support Smart Grid technologies at low lifecycle cost. Proven existing technologies with proven network protocols and architecture. Products that can support TNMP s service area geography, particularly very desolate meter locations. Q. ONCE THE BIDS WERE RECEIVED, HOW WERE THEY EVALUATED? A. Two teams were created: Core evaluation team and a Management evaluation team. The proposals were evaluated against TNMP business requirements, PUCT requirements, AMIT use case requirements, technical capabilities, financial soundness, vendor capability, vendor financial fitness, and proposed costs. Each proposal was scored against the requirements and cost evaluations. Vendor references were contacted and evaluated. Significant research was done on the vendor s products using blogs, internet research, and industry information about vendors ability to deliver product and solutions. Then, as there were not large differences in costs, final selections from the core evaluation teams were done on technical merit and capability. The recommendations were passed to the management evaluation team, which reviewed the presentations from the core team, with the final selection made by the management team. Q. WHAT FURTHER PROCEDURES WERE USED AFTER THE SHORT LIST OF PROPOSALS WERE SELECTED? A. As there were only two responses, no short list was created. Q. HAS TNMP ENTERED INTO THE CONTRACT FOR THE AMS? A. At this time, TNMP has negotiated terms and conditions with SmartSynch, but no specific contract or statement of work for an AMS implementation. TNMP is not under contract for an MDMS vendor. Q. IF TNMP HAS NOT ENTERED INTO CONTRACTS, IS TNMP PLANNING TO ENTER INTO CONTRACTS DUE TO THIS FILING? A. Yes. It is TNMP s intention to complete contract negotiations with all major suppliers associated with providing software, hardware, and services necessary to complete this

108 DIRECT TESTIMONY OF GARY L. KESSLER project. Specific negotiations will be completed by PNM Resources Supply Chain organization in behalf of TNMP. Q. WHAT PROCESS DID TNMP USE IN SELECTING A CONTRACTOR FOR METER INSTALLATION? A. The selected vendor, SmartSynch, contacted five industry experienced meter installation vendors. Each vendor was provided identical deployment requirements and asked to respond in writing with their respective implementation approach, deliverables, and price. Upon receipt of responses from all five vendors, they were asked to present their response to TNMP and SmartSynch, whereby they were scored and their response and experience weighted. With the field of five narrowed to the top two, a Scope of Work was provided by SmartSynch, outlining the requirements and best practices required for deployment, and both vendors were invited to provide best and final response and pricing. Upon receipt of their best and final responses, each of the two vendors were invited to present a second time to SmartSynch and an expanded TNMP management team, where their responses and experience were scored. A mutual decision for vendor of choice was made by SmartSynch and TNMP. 17 VI. ADVANCED METER CAPABILITIES Q. WHAT ARE THE FUNCTIONALITIES OF THE ADVANCED METERS INCLUDED IN TNMP S AMS DEPLOYMENT PLAN? The selected GE I210+c meter incorporates the appropriate technology and firmware to meet all of the functionality described in Substantive Rule (g). A manufacturers technical and users manual is included as an exhibit 12 to corroborate listed technology and functionality. The table below lists each requirement of Substantive Rule (g) and the technology embedded in the TNMP AMS and/or meter which enables the AMS to meet the rule requirement: 12 Exhibit GLK

109 DIRECT TESTIMONY OF GARY L. KESSLER 1 Rule Functionality AMS Technology (A) Automated or remote meter reading; The AMS provides a remote communications path using a cellular network and an embedded communication card within the GE I210+c meter. (B) Two-way communications; The SmartSynch communications card provides GPRS communications using AT&T Cellular network. (C) (D) Remote disconnection and reconnection for meters rated at or below 200 amps; The capability to time-stamp meter data sent to the independent organization or regional transmission organization ( RTO ) for purposes of wholesale settlement, consistent with time tolerance standards adopted by the independent organization or RTO; A 200 amp disconnect switch is built into the GE I210+c meter and is activated remotely from a head end server. The meter timestamps data in GMT format, consistent with RTO requirements and utilizes an atomic clock for time synchronization

110 DIRECT TESTIMONY OF GARY L. KESSLER Rule Functionality AMS Technology (E) (F) (G) The capability to provide direct, real-time access to customer usage data to the customers and the customer s REP, provided that: Hourly data shall be transmitted to the electric utility s web portal on a day-after basis.. The Commission Staff using a stakeholder process, as soon as practical shall determine, subject to Commission approval, when and how 15-minute interval recorder data shall be made available on the electric utility s web portal; Means by which the REP can provide price signals to the customer; The capability to provide 15-minute or shorter interval data to REPs, customers, and the independent organization or RTO, on a daily basis, consistent with data availability, transfer and security standards adopted by the independent organization or RTO; The AMS provides 115kbps access to the meter over a cellular GPRS connection. Hourly data is collected in the meter storage and transmitted to the utility on a daily basis. It is then processed and uploaded to the SMT webportal in accordance to the AMIT use cases currently under development. The AMS utilizes the cellular network to deliver a price signal to the meters Zigbee hardware, which is then broadcast to the customer s Zigbee device as defined in the developing AMIT HAN use cases. The AMS meter can collect 5 or 15-minute data for transmission to the head-end system on a daily basis

111 DIRECT TESTIMONY OF GARY L. KESSLER Rule Functionality AMS Technology (H) (I) (J) (K) On-board meter storage of meter data that complies with nationally recognized non-proprietary standards such as in American National Standards Institute (ANSI) C12.19; Open standards and protocols that comply with nationally recognized non-proprietary standards such as in ANSI C12.22, including future revisions thereto; Capability to communicate with devices inside the premises, including, but not limited to, usage monitoring devices, load control devices, and prepayment systems through a home area network, based on open standards and protocols that comply with nationally recognized nonproprietary standards such as ZigBee, HomePlug or the equivalent; and The ability to upgrade these minimum capabilities as technology advances and, in the electric utility s determination, become economically feasible. GE I210+c meters store meter data tables in ANSI format. This is stated on page one of the GE Energy GEH 7101 Users manual for the GE I210+c meter. The AMS had been selected because it supports open standards from the meter to the back-office. ANSI C12.22 will be implemented as available from SmartSynch. The SmartSynch communications board, installed inside the GE I210+c meter, utilizes protocol, which is currently used in the Zigbee and 6LoWiPAN communications stacks. The deployed meters will utilize a Zigbee SE1.0 compliant stack to communicate with in premises devices. The GE I210+c is fully over-theair (OTA) firmware upgradable, including the hardware used to provide in premise communications

112 DIRECT TESTIMONY OF GARY L. KESSLER Q. DO THESE ADVANCED METERS MEET THE TECHNOLOGICAL REQUIREMENTS OF PUC SUBSTANTIVE RULE (g)? A. Yes, the advanced meters to be deployed by TNMP pursuant to its AMS Deployment Plan provide the capabilities that comply with the AMS requirements outlined in Substantive Rule (g). There are, however, certain customer types and meter types where exceptions to those requirements are appropriate, and we are requesting in this proceeding a waiver which would relieve us of the obligation of installing a fully functional advanced meter that would have all of the functionalities contemplated by in those circumstances. We are requesting waivers for the following circumstances: Loads that may cause a safety or health issue if disconnected will not have an advanced meter with disconnect functionality installed. For example, we propose not to include the disconnection functionality for traffic lights, metered street lights, railroad crossings, police stations, hospital facilities, service points providing cathodic protection, and TNMP s emergency facilities. Loads that do not require and/or will never require a HAN device will not have an advanced meter with a HAN device installed. For example, we propose not to include a HAN device for traffic lights, metered street lights, and other applications that would not benefit from a HAN device, such as electric gates, communications power supplies, sprinkler controls, cathodic protection power supplies, and TNMP s emergency facilities. Loads that currently have poly-phase, class 200 (200 amp rating) meters, which includes commercial customers and some residential customers, will not have a service switch until a poly-phase meter with those devices becomes available in the market and are requested by the customer or designated REP. Loads that have poly-phase and instrument rated meters will not have a HAN device embedded in the meter. If poly-phase meters with HAN devices become available in the market, then TNMP shall review installing those meters on a requested basis by the customer or designated REP. As the ANSI Standard C12.22 has not yet been adopted, and is not widely deployed, the advanced meters and communication modules that TNMP is deploying may not initially

113 DIRECT TESTIMONY OF GARY L. KESSLER be compliant with that standard. TNMP intends to have the AMS (end-to-end) compliant with ANSI Standard C12.22 when the product upgrades are available from the vendor. All TNMP advanced meters have the proven capability to remote-upgrade meter firmware so that the Company can ensure that the advanced meters do comply with ANSI Standard C12.22 when the appropriate firmware is available from SmartSynch. Q. WHAT STEPS HAS TNMP TAKEN TO ENSURE THAT THE ADVANCED METERS WILL HAVE THE LONGEST POSSIBLE TECHNICAL LIFE? In the selection of SmartSynch, TNMP evaluated all technologies available in the market place to understand the most robust technology for the TNMP service area. As part of the evaluation, one of the key requirements that emerged is future-proofing of the technology. At the expense of some initial upfront cost, but to ensure a lower asset lifecycle cost, TNMP chose to avoid metering technologies that had embedded communications on the meter board. Instead, TNMP has pursued a modular approach, where each meter has an under glass communication module that is installed into a meter chassis. Figure GK 4 depicts an installed communications module inside a GE I210+c meter. These modules can be removed and retrofitted with newer communications and hardware functionality. The current update process for TNMP is a retrofit process. AMS meters would be replaced with new technology over a 2-7 year period as part of the normal meter testing process required by the PUCT. Each removed meter would be replaced by a meter containing newer technology. The removed meter(s) would be shipped to the factory for retrofit and recertification. The retrofitted meters would then be returned to TNMP, placed in inventory, and reinstalled in the field. This process requires TNMP to purchase a small number of newer technology meters for initial installation, but appears to be the most cost-efficient use of equipment and resources for TNMP and the ratepayers. 26 VII. BACK-OFFICE SYSTEMS Q. WHAT ARE THE BACK-OFFICE SYSTEMS BEING DEPLOYED IN CONNECTION WITH THE DEPLOYMENT OF ADVANCED METERS? A. Implementation of AMS will require TNMP to perform a complete enterprise retrofit of the back-office systems. TNMP will not replace its CIS, but will need to install a Meter Data management system from Itron and an Outage Management system from MilSoft to

114 DIRECT TESTIMONY OF GARY L. KESSLER manage meter alarms and create work orders for actionable events created by the AMS. In addition, TNMP will need to install a new complex billing system to support creation of EDI billing data for 15-minute increments. In addition, SmartSynch s TMS meter reading server and software will require integration into the back-office. There will be significant work required to integrate all these systems together in order to communicate effectively with the Smart Meter Texas Web portal and existing TNMP legacy systems. New systems integrated are: Itron s Enterprise Edition Meter Data Management Itron s Complex Billing System and Interval Data Capture MilSoft s DisPatch Outage Management System SmartSynch s Transaction Management System (Meter Reading Server) Q. WHAT MODIFICATIONS TO THE EXISTING BACK-OFFICE SYSTEMS ARE NECESSARY TO SUPPORT THE PROPOSED AMS? A. The following have to occur to support the proposed AMS solution: 1. Purchase and install a new Meter Data Management System (MDMS) 2. Purchase and install a new Complex Billing System to support interval data billing. 3. Purchase and install new Outage Management System (OMS) to support reading, routing, and management of AMS Meter alarms 4. Integration of new systems with TNMP s existing systems. This will require extensive work to allow the new systems to share data with Banner (CIS), GIS, the Meter Head-End System (TMS), Texas Common Portal, Meter Inventory System, EDI Transaction management system, and TIBCO Enterprise Data Transport. 5. Modifications to TNMP s EDI Gateway and Banner (Customer Information System) will be required so that these systems can handle messages and information required by new AMS market rules associated with EDI transactions to ERCOT. Q. WHAT SYSTEMS RELATED TO THE TEXAS MARKET TRANSACTIONS WILL NEED MODIFICATIONS TO SUPPORT THE PROPOSED AMS? A. Modifications to TNMP s EDI gateway, Banner, Meter Head-End System (TMS) and TIBCO are required to support the Texas Market Transaction

115 DIRECT TESTIMONY OF GARY L. KESSLER Q. ARE THERE ASPECTS OF THE CURRENT IT HARDWARE AND SOFTWARE INFRASTRUCTURE THAT WILL NEED TO CHANGE TO SUPPORT THE PROPOSED AMS? A. Yes, new acquisition of Hardware and Software is needed to support TNMP s AMS program. All new systems listed above will require both hardware servers and software purchases. Legacy support software and databases, such as Oracle will also require potential license negotiation as the MDMS and OMS will utilize these packages, therefore requiring more licenses. Q. HAS TNMP ENTERED INTO ANY CONTRACTS TO PURCHASE THESE SYSTEMS? A. No contracts have been established to purchase any systems. The vendors for the new systems have provided quotations only and have not been contracted to provide goods and services. This will occur after the approval of this filing. Q. IS TNMP PLANNING TO USE A THIRD-PARTY SYSTEMS INTEGRATOR TO ASSIST WITH ANY OF THE IT EFFORTS? A. Yes, TNMP will use the following (currently identified)third-party vendors namely: 1. Meter Head-End System Vendor: Itron 2. Meter Data Management Product Vendor: SmartSynch 3. Complex Billing System Product Vendor: Itron 4. System Integrator for Back-Office Integration: To Be Determined. Q. WILL THE COMMON AMS WEB PORTAL BE AVAILABLE UPON TNMP S INITIAL AMS METER DEPLOYMENT? A. The Smart Meter Texas Web portal will not be available with TNMP data upon TNMP s initial meter deployment. TNMP data will be available in the common web portal after the implementation of TNMP Back-Office systems. Public information relating to the Web portal can be found at the Public Utility Commission of Texas web site at the following URL link: Q. WILL THE BACK-OFFICE SYSTEMS AND AMS WEB PORTAL FUNCTIONS BE AVAILABLE FOR THE INITIAL AMS DEPLOYMENT?

116 DIRECT TESTIMONY OF GARY L. KESSLER A. No. These are capital intensive projects which TNMP cannot begin spending for until approval of the deployment plan. Q. PLEASE DESCRIBE THE SECURITY FEATURES THAT THE AMS WEB PORTAL IS EXPECTED TO HAVE. A. Security features for the common AMS Web Portal developed by IBM is defined by the Portal Security Requirements. The following Security features for the Integration between TNMP and Texas AMS Web Portal will be implemented: Web Security: One-way HTTPS/SSL transport security for all data sensitive communications between the TNMP & AMS Web Portal Web Services Security: WS-Security over HTTPS/SSL transport security with possible all/part SOAP message encryption for communications between TNMP and AMS Web Portal FTP Security: Secure FTP communication with two-way SSL for communication b/w TNMP & AMS WEB PORTAL Q. WILL TNMP MAKE PERIODIC REPORTS TO THE COMMISSION REGARDING DEVELOPMENT AND DEPLOYMENT OF THE AMS WEB PORTAL? A. Yes, TNMP will make periodic reports to the commission as part of the overall deployment per requirement in Substantive Rule Q. TO DATE, HAS TNMP INCURRED COSTS ASSOCIATED WITH THE AMS WEB PORTAL OR ANY OTHER SYSTEMS AS PART OF THE PILOT? A. Yes, TNMP has incurred cost associated with the AMS Web Portal; this includes participation in the Smart Meter Texas (SMT) program (Texas Common Portal Meeting, HAN Meetings). TNMP has also incurred cost in evaluating a suitable Meter Data Management Product Vendor, Complex Billing System product vendor, RFI, and RFP generation. Q. ARE THESE SYSTEMS CRITICAL TO THE DEPLOYMENT OF ADVANCED METERS?

117 DIRECT TESTIMONY OF GARY L. KESSLER A. Yes. These are the core systems required to effectively acquire, process, and publish AMS data to the Smart Meter Texas Web Portal, create billing data for the REP, and to meet all necessary AMIT business use cases and TNMP operational requirements. Currently, TNMP has no back-offices systems that can support any functionality of AMS as defined in the current rule. This project would require installing and integrating all of the above mentioned back-office systems in order to comply with Substantive Rule VIII. CONCLUSION Q. PLEASE SUMMARIZE YOUR CONCLUSIONS REGARDING THE MODIFICATIONS AND ENHANCEMENTS TO THE BACK-OFFICE SYSTEMS, THE CHANGES TO EXISTING IT INFRASTRUCTURE, AND THE WEB PORTAL. A. Based on my experience, knowledge, and review, the modifications and enhancements to the IT systems that I have described are required to support the proposed AMS and the estimated costs that I sponsor for these activities are reasonable and necessary. Q. IS THIS THE CONCLUSION OF YOUR TESTIMONY? A. Yes

118 118

119 GE Energy Exhibit GLK-1 Page 1 of 4 I-210+c Singlephase Meter 119

120 I-210+c Singlephase Meter Exhibit GLK-1 Page 2 of 4 The I-210+c is the latest addition to GE Energy s singlephase advanced meter family offering features beyond basic energy such as demand, time of use, and load profile recording. It is GE s most robust and flexible meter, designed to offer utilities the ability to customize to suit their specific needs adding or subtracting as much functionality as conditions require. The I-210+c also comes with the option of an integrated, factory-installed remote disconnect switch to help utilities more efficiently address issues such as non-payments, move-in, move-outs, and demand side management. The meter is also offered in network forms allowing utilities to more cost-effectively meter network services. The meter s hardware and software platforms are designed to be highly versatile, offering plug-n-play capabilities for many features. In its simplest configuration, the I-210+c can act as a basic energy meter, with no additional functionality. The design of the meter allows for easy upgrade of virtually all of the additional metering functionality available (with the exception of remote connect/disconnect, which must be installed at the time of order, at the GE factory). In its most robust configuration, the I-210+c acts as a flexible, advanced meter uniquely qualified to suit the needs of a dynamic utility environment. Softswitches With the addition of a softswitch, the I-210+c can be enabled with advanced metering functionality and/or become compatible with a suite of third-party AMI solutions. The softswitch, which is a software application used to enable the meter with additional functionality, can be loaded onto the meter at the time of order or after the meter has been put in service to add additional functionality to the meter. Features such as time-of use, cycle insensitive demand, load profile recording, AMI communications, and event logging can be added. I-210+c Available Softswitches: T 2 : Time-of-Use E 2 : Event logging of up to R 2 : Demand and load profile 200 events recording (2-channel) Q 2 : Power quality activates K 2 : Second measure low voltage monitoring A 2 : Alternate communications (AMI modules or other communication devices) AMI Plug-n-Play Many utilities are in the process of making AMI related decisions and many have chosen to utilize more than one AMI solution to effectively manage the needs of their service territory. For these reasons, the I-210+c has been designed to allow for the interchangeability of AMI modules (that GE is compatible with). AMI communications can be added at the GE factory, added after the fact, or changed out and replaced with another compatible AMI module should the meter be redeployed to another part of the service territory. Cycle Insensitive Demand With the appropriate softswitches enabled, the meter can be set to calculate Cycle Insensitive Demand based on a GE-proprietary algorithm. This provides an alternative method for calculating the maximum demand where one-way AMI systems are employed, and eliminates the need for manual demand reset with 1-way AMI systems. This feature eliminates a significant limitation impacting utilities that have implemented, or who are considering implementing one-way AMI systems. 120

121 Exhibit GLK-1 Page 3 of 4 MeterMate* Meter Reading and Programming GE Energy s MeterMate software is compatible with the I-210+c and provides unparalleled flexibility for customers to read and customize their I-210+c. Some advanced features allow the user to: Change factory program Select Demand, Demand/LP defaults including or TOU modes of operation measurement detents and the use of the program Set or change sag and manager to create and edit swell thresholds programs for the selected modes of the meter Perform a master reset to clear energy values, voltage Transfer programs created event and power fail counters in the MeterMate system to the I-210+c meter using Obtain a meter program and MM Comm data summary report * The meter is equipped with technology to more fully address a utility's saftey concerns while ensuring the most efficient use of resources and protecting its revenues. Remote Connect/Disconnect The I210+c can be ordered with an integrated remote connect/disconnect switch mounted under the meter's cover. This is a factory installed option that must be specified at the time of order. To take advantage of all of the functionality this option offers, a two-way AMI device and system should be employed. This functionality is ideal for: State-of-the-Art Tamper Detection The I-210+c has an optional Event Log feature which captures information about the 200 most recent events that happen in the meter including reverse energy flow (caused by meter inversion). This can be used to check for confirmation of meter action or evidence of tampering. I-210+c has enhanced features to help utilities improve the level of service they provide their customers. IEEE Reliability Indices The I210+c has an optional power quality feature (activated when appropriate softswitches are added) that provides support for calculating IEEE reliability indices (such as MAIFI, SAIFI, etc.) by collecting momentary and sustained interruptions and the accumulated duration of sustained interruptions. Interval Recording The interval recording option (which is enabled via a softswitch), in addition to being used as a billing tool for the utility, can be used as a customer service tool which can provide the customer with useful data regarding their energy consumption. Meter specifications and related information I210+c Meter ANSI forms: Form Class Volts 1S & 240 Locations with frequent move-in/move-outs and locations that are undesireable or dangerous. With this switch, the utility will be able to remotely connect or disconnect service and avoid sending a technician to the site Situations involving non-paying customers New applications such as demand side management, emergency conservation, prepayment systems, customer system premises protection, and controlled outage restoration 2S 200 & S & 3CS & 240 4S S 200 & & S 200 & & 240 A single polycarbonate cover is available with either of two variants including: With RESET latch and Optocom D ring Plain cover without RESET or D ring 121

122 Exhibit GLK-1 Page 4 of 4 I-210+c Display Performance meets or exceeds ANSI C12.1, C12.10, C12.20, C Operating Range: Voltage: +20% -20% (or ±20%) Temperature: -40 C through +85 C Typical Starting Watts: <=5.0 Watts (Form 2S 240V CL200) Typical Watts Loss: 0.7 Watts Typical Accuracy: Within +/- 0.2% For more information, please contact us via at energy.tdsolutions@ge.com, or visit our web site at ge.com/energy * trademarks of General Electric Company ANSI is a registered trademark of American National Standards Institute, Incorporated. IEEE is a registered trademark of the Institute of Electrical Electronics Engineers, Inc General Electric Company. All rights reserved. GEA (03/07) 122

123 GE Energy Exhibit GLK-2 Page 1 of 42 GE I210+c Electronic Meter Product Description, Operating Instructions, Maintenance Instructions, Upgrading. 123

124 Exhibit GLK-2 Page 2 of

125 Exhibit GLK-2 Page 3 of 42 Notice The information contained in this document is subject to change without notice. GE makes no warranty of any kind with regard to this material, including, but not limited to, the implied warranties of merchantability and fitness for a particular purpose. GE shall not be liable for errors contained herein or incidental consequential damages in connection with the furnishing, performance, or use of this material. This document contains proprietary information that is protected by copyright. All rights are reserved. No part of this document may be photocopied or otherwise reproduced without consent of GE by General ELectric Company. Published in a limited copyright sense; all rights, including trade secrets, are reserved. Document Edition First 04/2007 I210+c, Lexan, MeterMate, and SMARTCOUPLER are trademarks of GE. FCC COMPLIANCE STATEMENT This product generates and uses radio frequency energy. It has been tested and verified that it complies with the limits for the Code of Federal Regulations (CFR) 47, Part 15 Radio Frequency Devices, Subparts A General and B Unintentional Radiators issued by the Federal Communications Commission for Class B digital devices. If, however, the product causes radio or television interference, notify: Manager Technology General Electric Company 130 Main Street Somersworth, NH GE Energy GEH 7101 (11/07) 125

126 Exhibit GLK-2 Page 4 of 42 GE Energy GEH 7101 (11/07) 126

127 Contents Exhibit GLK-2 Page 5 of Product Description General Information Physical Description Meter Forms Physical Variants Available Voltage Ratings Time Base Hardware Options Demand Operating Mode Demand/Load Profile Operating Mode TOU/Demand Operating Mode TOU/Demand and Load Profile Operating Modes On-site User Features Operation Maintenance Advanced Features and Soft-switches Programming and Reading Software Technical Information Theory of Operation Sensing Devices Metering Chip Microcomputer Nonvolatile Memory Power Supply Time Keeping Battery AMR Modules Operating Instructions Nameplate Information and Labels Labels Display Information Display Modes Display Switch Actions Normal Display Mode Alternate Display Mode Test Mode Frozen Display Mode Liquid Crystal Display Information Display Examples kwh Display Alternate Display Mode Test Mode Display GE Energy GEH 7101 (11/07) 127

128 3. Maintenance Instructions Exhibit GLK Page 6 of 42 Recommended Procedures Meter Testing Tools Calibration LED LCD Display Test Mode Starting the Test Mode Operation During Test Mode Energy Calculations Displays Available in Test Mode Only Test Reset Exiting Test Mode Field Accuracy Test Field Testing with Test Mode Maximum Demand Reading Testing Disk Analog Testing Shop Test Meter Shop Equipment Equipment Setup Test Constant Watt-hour Test Procedure Var-hour Testing Battery and Super Capacitor Replacement Replacing the Battery Replacing the Super Capacitor Service Repair Returning a Meter Cleaning Storage Troubleshooting Guide Errors and Cautions Error Reporting Er Battery Failure & Power Outage Er Hardware Failure Er Non-volatile Data Error Er Firmware Code Error Er Meter Chip Error Caution Reporting CA Low Battery CA Unprogrammed CA Loss of Program CA Unprogrammed and Loss of Program CA DC Detected CA Low Potential CA DC Detected and Low Potential CA Demand Overload CA Leading kvarh CA Received kwh

129 4. Upgrading Exhibit GLK Page 7 of 42 General Soft-switches Alternate Communication A2 Soft-switch Event Log E2 Soft-switch KVA and Kvar Measurements K2 Soft-switch Demand N2 Soft-switch Power Quality Measurements Q2 Soft-switch Basic Recording R2 Soft-switch Time Of Use T2 Soft-switch Converting from Demand to Demand/LP or TOU Mode Meter Disassembly Removing the Meter Cover Removing the Electronics Module Meter Reassembly Site Guides Diagrams Figures Figure 1-1: The I210+c Meter Figure 1-2: I210+c Meter Block Diagram Figure 2-1: Meter Nameplate Figure 2-2: Alternate Display Mode Switch Figure 2-3 Reset and Test Switches Figure 2-4: Liquid Crystal Display Information Figure 2-5: kwh Display Figure 2-6: Alternate Display Figure 2-7: Test Mode Display Figure 3-1: Optical Port Figure 3-2: Liquid Crystal Display Figure 4-1: Exploded View of I210+c Meter Figure 6-1: ANSI Meter Diagrams Tables Table 1-1: ANSI Standard Meter Forms Table 2-1: User-Selected Display Information Table 3-1: Default Test Mode Values Table 3-2: Test Mode Default Display Table 3-3: Error Code Display Table 3-4: Caution Code Display Table 3-5: Fault Symptoms Without Codes Table 4-1: I210 Demand/TOU Soft-switches Equations Equation 3-1: Accumulated Watt-hours Calculation

130 Exhibit GLK-2 Page 8 of Product Description GE s I210+c meter is an electronic, single-phase or network, demand and time-of-use (TOU) electricity meter intended primarily for residential applications. Provides up to four distinct TOU tiers, allowing time-of-use energy and demand values to be calculated for specific time periods, in addition to the overall energy and demand calculations. Also supports up to four seasons. Each season can have up to three day-types and one holiday day-type. The meter can store a total of 80 distinct tier switches. Includes a calendar with up to 50 programmable dates for specifying when daylight savings time changes, season changes, self-reads, demand resets, and holidays are to occur. Supports load profile recording for up to two channels. Provides memory for two self-reads Includes a test mode Provides both immediate and pending real-time pricing commands via communications. Supports ANSI Standards C12.18 and C12.19 Figure 1-1: The I210+c TM Meter The I210+c meter provides a wide range of additional features including: an extended range of software-configurable features (soft-switches); accurate timekeeping with the presence of an optional super capacitor or battery; enhanced energy, demand, and time-of-use billing measures; load profile recording; self-read capability; demand reset support; test mode; real-time pricing functionality; and rolling status and rolling billing period functions. 1.1 General Information The I210+c meter is similar to the I210+ meter in physical construction while providing additional features as follows: May be configured for various metering needs: demand-only metering, demand/load profile (LP) metering, TOU or TOU/demand metering, TOU or TOU/demand meter with load profile metering. Supports AMR communications with any of above configurations. Supports up to two summations from the following: delivered-only kwh, received-only kwh, delivered + received kwh, delivered - received kwh, lagging-only kvarh, leading-only kvarh, lagging + leading kvarh, lagging leading kvarh, phasor apparent kvah, phase A line-to-neutral voltage. The values chosen for summations must be the same as the values used in demand and load profile recording. The I210+c meter additionally incorporates several new features enhancing its capability. The rolling billing period feature provides up to two peak demands over a programmable period of time. The meter stores the overall daily peak demands, as well as the daily peak demands for two tiers, for the last 35 days. The peak demands are available for reading and display. Rolling status provides the cautions and errors that have occurred in the meter over the last programmable number of days. The meter stores the daily caution and error flags for the last 35 days. Rolling status is available for reading. DC detection is available as a meter caution. The meter will detect the presence of DC in the current signal. This caution can be selected for display and for reporting in the event log Physical Description The I210+c meter uses a clear polycarbonate cover that is molded in one piece. Two types of covers are available, one with an integrated ANSI Type 2 optical communications port and a demand reset mechanism in the cover, and one without these two features. The meter base assembly provides direct interchangeability with existing ANSI form single-phase meters. This standardization allows retrofit to existing installations and use with existing ring and ringless sockets. GE Energy GEH 7101 (11/07) 130 1

131 Exhibit GLK-2 Page 9 of 42 The nameplate displays all information required by ANSI, including an area for customer-specific information. A liquid crystal display is provided to indicate energy consumption and various other data. The display is covered in detail in Chapter 2, Operating Instructions. An Alternate Display Switch, located on the right side of the meter face slightly above the one o clock position, may be activated by a magnet. The switch and its use are also described in detail in Chapter 2, Operating Instructions. The Demand Reset and Test switches are located at the two o clock position of the meter face. The Test Switch has no external access. The cover must be removed to operate the switch. An ANSI Type 2 optical port is located in the three o clock position of the meter face. The optical port allows a computer to communicate with the meter for reading and programming using Standard Tables (ANSI C12.19) and PSEM (Protocol Specification for Electricity Meters [ANSI C12.18]). The I210+c optical port operates at a fixed baud rate of The battery for the time-of-use option is visible at the 12 o clock position. It is the industry-standard battery. An optional super capacitor is available instead of a battery Meter Forms The mechanical configuration allows the meter to be directly interchanged with existing ANSI form single-phase and network meters. The standardization allows retrofitting to existing installations and use with existing ring and ringless sockets Physical Variants Available The description of the meter and the available S-base forms have been provided below. Table 1-1: ANSI Standard Meter Forms The Form 2S is available with or without the test link. Form Wires Circuit Elements SC/TR Class 1S 2 1Ø 1 SC 100 2S 3 1Ø 1 SC 200 or 320 3S 2 1Ø 1 TR 20 4S 3 1Ø 1 TR 20 12S 3 Network or 3ØΔ 2 SC 200 or S 3 Network 2 SC 200 or Voltage Ratings The standard meter voltage rating is either 120 or 240 VAC with +/-20% line voltage variations. The meter will maintain an accuracy of 0.5% with line voltage variations of +/-10% from normal per ANSI C Time Base The standard meter keeps time from the line frequency. The meter may be programmed to use a crystal oscillator for timekeeping in areas where line frequency does not provide adequate stability for line-based timekeeping Hardware Options The I210+c meter supports optional add-on AMR communication modules Demand Operating Mode The basic I210+c meter has several operating modes. It is not necessary to buy different versions of the meter to get these features; all modes are built into every meter. Demand mode is the most basic mode of operation. Demand mode does not require a battery. The demand soft-switch, N, must be enabled. The basic meter in demand mode provides: Energy measurement (two quantities) Demand (two quantities - block, or rolling demand, maximum, cumulative, and continuously cumulative displays). Alternatively, up to two thermal demand measures are also available. Fundamental-plus-harmonics measurements only Bidirectional energy measurements with various detenting choices Self-monitoring of meter operation for error conditions and caution conditions. Alternate display scroll Test mode, to test meter operation and site characteristics without affecting billing quantities or load profile data. Programming seal function for enhanced security (Canadian requirement) Security table of key meter events Up to two self-reads Demand reset support GE Energy GEH 7101 (11/07) 2 131

132 Exhibit GLK-2 Page 10 of 42 Programmable event logging Real-time pricing support Immediate real-time pricing activation through communications Support for ANSI Standards C12.18 and C Demand/Load Profile Operating Mode Demand/load profile mode requires a battery or super capacitor and the R2 load profile recording soft-switch. The following features are provided in addition to the basic features provided by the meter in demand mode: Load profile recording for up to two channels Daylight savings time change support TOU/Demand Operating Mode TOU/demand mode requires a battery or super capacitor and the T2 time-of-use soft-switch. The following features are provided in addition to the basic features provided by the meter in demand mode: Programmable daily tier schedules for time-of-use support Programmable calendar for scheduling holidays, daylight savings adjustments, season changes, demand resets, and self-reads Pending real-time pricing activation through communications Rolling billing period support Rolling status TOU/Demand and Load Profile Operating Modes TOU/demand and load profile mode requires a battery or super capacitor and the T2 time- of-use and R2 load profile recording soft-switches. The following features are provided in addition to the basic features provided by the meter in TOU/demand mode: Load profile recording for up to two channels On-site User Features Operation The I210+c meter has several features for ease of use on site, including: Nameplate and label information Numeric display with key annunciators, and several display modes including normal, alternate and test Maintenance The I210+c meter is designed for unattended operation over a long life. When the meter or the site requires attention, the meter has features to facilitate these tasks. Many modes of operation and enhanced functions are built into the meter software and may be enabled without physical change to the meter. Upgrading from demand to demand/load profile or time-of-use operation requires no added hardware, aside from the battery or super capacitor that supports timekeeping during power outages. Disk analog on the display for field calibration testing. Test mode for convenient calibration testing without affecting billing data. Self-test of meter operation Flexible control of display for error conditions and cautions in the meter. Maintenance instructions are covered in Section 3 of this manual Advanced Features and Soft-switches Many advanced features of the I-210+c meter can be enabled with soft-switches. Soft-switches are logical controls that enable related groups of meter features. Without activation of a soft-switch, operation of the controlled features is suppressed. Soft-switches may be enabled in the meter as shipped from the factory, or may be turned on at any time by the use of MeterMate software. The following soft-switches are available in the I-210+c meter: E2 Switch Event log K2 Switch Kvar and kva measures Q2 Switch Power quality measures R2 Switch Two-channel recording T2 Switch Time-of-use N2 Switch Billing demands A2 Switch Alternate communications Operating features controlled by soft-switches are described in Section 4, Upgrading. GE Energy GEH 7101 (11/07) 3 132

133 Exhibit GLK-2 Page 11 of Programming and Reading Software The meter is supported by the MeterMate software suite. This software facilitates setting up and using many meter features: Creation of custom meter programs Loading programs into the meter Setting site-specific meter parameters Viewing real-time data Reading meter data Load profile data analysis and reporting Meter program and meter data reporting Batched meter communications Meter mode conversion and soft-switch upgrading Refer to Reading and Programming Instruction manual for MeterMate (GEH-5084I MeterMate MMCOMM Instruction Book). 1.3 Technical Information This section contains the theory of operation and general circuit configuration of the GE I210+c meter Theory of Operation The theory of operation of the I210+c meter is described in conjunction with the block diagram shown in Figure Sensing Devices Voltages are sensed by high-impedance resistive voltage dividers. Currents are sensed by up to two current transformers, each feeding to the current signal sampling circuit. The sensors provide scaled signals to the metering chip Metering Chip The voltage and current sampling, signal processing, and basic meter calculations are performed by the metering chip. The meter chip has a 22-bit delta-sigma ADC with an effective sampling rate of 2520 samples per second. It has two voltage and two current inputs, so it can meter single-phase and network services. The metering chip also drives the meter s LCD, provides real-time clock functionality, and drives the meter s calibration pulse. Figure 1-2: I210+c Meter Block Diagram 133 4

134 Exhibit GLK-2 Page 12 of Microcomputer The microcomputer is a 32-bit expandable single chip microcomputer. It receives basic metering data (Wh, varh, V2h) and status information from the Teridian meter chip every second. The microcomputer performs all of the high level metering functions such as summations, demand calculations, time-of-use functions and load profile recording. It also provides the communications interface to the optical port and the AMR communication port Nonvolatile Memory The I210+c meter is equipped with two 32K x 8 EEPROM devices. All data values and program parameters are stored in these EEPROMs; a battery is not required for data storage. Meter data quantities are updated at each power fail event. Stored data is constantly checked to detect errors Power Supply The I210+c meter is powered from the A-phase voltage line. It has a solid-state switching type power supply. The meter is available in two voltage ratings: 120V or 240V, +/-20% of rating. The supply operates for either 50Hz or 60Hz line frequency. (Note: the frequency at which the meter will operate is factory configured, it is not user programmable.) Caution: Do not exceed 288 volts RMS on the power supply voltage input terminals Time Keeping Battery A standard 3.6V, half-size AA, lithium battery maintains the meter clock when the meter is programmed as a time-of-use meter or demand meter with load profile recorder. Since all billing and programming information is stored in nonvolatile memory, the battery is primarily used for maintaining date and time information during a power outage. Under normal conditions, the battery should provide more than one year of service during outage conditions (time on battery backup) and more than 10 years of service during storage conditions (disconnected from terminals) or when properly installed in an energized meter. A super capacitor is also available and may be ordered in place of a battery. The super capacitor, when fully charged, will provide a minimum of eight hours of backup. It is charged from the meter s power supply AMR Modules In order to support meter communications with AMR modules, the basic meter provides a connector containing a power fail signal and power for AMR modules. Note: Only AMR vendors with Non-Disclosure Agreements with GE, providing modules tested by GE, will be considered within the warranty agreement. GE Energy GEH 7101 (11/07) 5 134

135 Exhibit GLK-2 Page 13 of 42 Figure 2-1: Meter Nameplate 2. Operating Instructions 2.1 Nameplate Information and Labels The I210+c meter will include all ANSI-required nameplate. An area specified by ANSI shall be available for customer information and bar code data when it is provided by the customer. Meters that incorporate AMR devices will include the AMR device ID (or serial number, as appropriate) either on the meter nameplate or on a separate nameplate. Month and two-digit year of manufacture will be included along with the assembly. Nameplate Multiply By shall be printed with the appropriate display multiplier filled in on any factory-programmed meter with a display multiplier other than one Labels Space for AMR vendor-specific labels is also available on the nameplate. See Figure 2-1 for details. 2.2 Display Information A maximum of up to 75 items can be selected for display from a total of 397 different user-selectable quantities. As the meter is very flexible, a wide range of quantities can be defined for mapping to meter calculations and display. In the table below UOM refers to Unit of Measure, a general term for measurements that can be displayed as defined by the meter program. UOM quantities can be kwh or other integrating voltamp quantities (such as kva) or voltages. Provision has been made to allow an additional nameplate and/or label for AMR devices per FCC or other statutory guidelines. See Figure 2-1 for a graphic representation of the meter nameplate. The meter nameplate is found on the front of the meter. GE Energy GEH 7101 (11/07) 6 135

136 Table 2-1: User-Selected Display Information Exhibit GLK-2 Page 14 of 42 Display Item Operational Modes Available Current Season Maximum 1,2 UOM: Maximum Demand All Maximum Demand Date TOU Maximum Demand Time TOU Maximum Demand Rate A,B,C,D TOU Maximum Demand Rate A,B,C,D Date TOU Maximum Demand Rate A,B,C,D Time TOU Cumulative 1,2 UOM: Cumulative Demand All Cumulative Demand Rate A,B,C,D TOU Continuously Cumulative 1,2 UOM: Continuously Cumulative Demand All Continuously Cumulative Demand Rate A,B,C,D TOU Summations 1,2 UOM: Total Summation All Summation Rate A,B,C,D TOU Instantaneous: Momentary Interval Demand All Momentary Interval Power Factor All Momentary Interval Va RMS fundamental plus harmonics All Momentary Interval V C RMS fundamental plus harmonics (network meters only) All Previous Interval 1,2 UOM: Previous Interval Demand All Rolling Billing Period Demand 1,2 UOM: Maximum Demand for Peaks 1 and 2 TOU Maximum Demand Date for Peaks 1 and 2 TOU Maximum Demand Time for Peaks 1 and 2 TOU Maximum Demand Rate A,B for Peaks 1 and 2 TOU Maximum Demand Rate A,B Date for Peaks 1 and 2 TOU Maximum Demand Rate A,B Time for Peaks 1 and 2 TOU Cumulative Demand for Peaks 1 and 2 TOU Cumulative Demand Rate A,B for Peaks 1 and 2 TOU Daily Maximum Demand TOU Daily Maximum Demand Time TOU Daily Maximum Demand Rate A,B TOU Daily Maximum Demand Rate A,B Time TOU Display Item Previous Season Maximum 1,2 UOM: Maximum Demand Maximum Demand Date Maximum Demand Time Operational Modes Available TOU TOU TOU Maximum Demand Rate A,B,C,D TOU Maximum Demand Rate A,B,C,D Date TOU Maximum Demand Rate A,B,C,D Time TOU Cumulative 1,2, UOM: Cumulative Demand TOU Cumulative Demand Rate A,B,C,D TOU Summations 1,2, UOM: Total Summation TOU Summation Rate A,B,C,D TOU Rolling Billing Period Demand 1,2 UOM: Maximum Demand for Peaks 1 and 2 TOU Maximum Demand Date for Peaks 1 and 2 TOU Maximum Demand Time for Peaks 1 and 2 TOU Maximum Demand Rate A,B for Peaks 1 and 2 TOU Maximum Demand Rate A,B Date for Peaks 1 and 2 TOU Maximum Demand Rate A,B Time for Peaks 1 and 2 TOU Cumulative Demand for Peaks 1 and 2 TOU Cumulative Demand Rate A,B for Peaks 1 and 2 TOU Last Reset Maximum 1,2, UOM: Maximum Demand All Maximum Demand Date TOU Maximum Demand Time TOU Maximum Demand Rate A,B,C,D TOU Maximum Demand Rate A,B,C,D Date TOU Maximum Demand Rate A,B,C,D Time TOU Cumulative 1,2 UOM: Cumulative Demand All Cumulative Demand Rate A,B,C,D TOU Summations 1,2, UOM: Total Summation All Summation Rate A,B,C,D TOU Rolling Billing Period Demand 1,2 UOM: Maximum Demand for Peaks 1 and 2 TOU Maximum Demand Date for Peaks 1 and 2 TOU Maximum Demand Time for Peaks 1 and 2 TOU GE Energy GEH 7101 (11/07) 7 136

137 Exhibit GLK-2 Page 15 of 42 Maximum Demand Rate A,B for Peaks 1 and 2 TOU Maximum Demand Rate A,B Date for Peaks 1 and 2 TOU Maximum Demand Rate A,B Time for Peaks 1 and 2 TOU Cumulative Demand for Peaks 1 and 2 TOU Cumulative Demand Rate A,B for Peaks 1 and 2 TOU Real Time Pricing (RTP) 1,2 UOM: RTP Maximum Demand Dmd/ DmdLP RTP Cumulative Demand Dmd/ DmdLP RTP Summation Dmd/ DmdLP Last Reset Last Reset RTP Maximum Demand Dmd/ DmdLP Last Reset RTP Cumulative Demand Dmd/ DmdLP Last Reset RTP Summation Dmd/ DmdLP SECURITY LOG Number of Bad Passwords All Number of Demand Resets All Number of EEPROM Writes All Number of OPTOCOM Communications All Number of Power Outages All Number of Times Programmed All Number of Times for Real-Time Pricing Entries All Cumulative Power Outage Duration in seconds TOU/DmdLP Date of Last Calibration All Time of Last Calibration All Date of Last Demand Reset TOU Time of Last Demand Reset TOU Date of Last OPTOCOM Comm. TOU Time of Last OPTOCOM Comm. TOU Date of Last Power Outage TOU/ DmdLP Time of Last Power Outage TOU/DmdLP Date of Last Programming All Time of Last Programming All Date of Last Real-Time Pricing Entry TOU Time of Last Real-Time Pricing Entry TOU Date of Last Time Change TOU Time of Last Time Change TOU TEST MODE Test Mode Demand Interval length in minutes (block) All Test Mode Demand No of Subintervals. (rolling only) All Test Mode Demand Subint. length in minutes (rolling) All Test Mode Maximum Demand 1,2 UOM All Test Mode Time Out Length in minutes All Test Mode Thermal Interval Type: 0 =15 min., 1 =1 min. All Test Mode Accumulating Demand 1,2 UOM All Test Mode Power Factor All Time Remaining in Test Mode (Sub)interval in min. & sec. (Not valid for thermal demands) All CONSTANTS Demand Interval Length in minutes (block only) All Demand No. of Subintervals (rolling only) All Demand Subinterval Length in minutes (rolling only) All Demand Delay Length in minutes All Minimum Outage for Demand Delay in seconds TOU Display Demand Units ( 0 =kw,kva, etc.; 1 =W,VA,etc.) All Display Scalar: (for GE internal use) All Display Primary Volts/Amps Flag: 0 = Sec, 1 = Pri. All Display Multiplier (Scaled): (for GE internal use) All Meter ID 1 All Meter ID 2 All Program ID All Transformer Ratio Current: X:5 All Transformer Ratio Voltage: X:1 All EOI Duration in seconds All Load Profile # Channels TOU/ DmdLP Load Profile Interval Length in minutes TOU/ DmdLP Real-Time Pricing State: 0 = Disabled, 1 = Enabled All Seal Flag State: 0 = Unsealed, 1 = Sealed Official Government Metrology Control All Blank Data Display All All Segments All Firmware Version No. = 1, 2, All Hardware Version No. = 1, 2, All Transformer Factor All Network Status Info All VARIABLES Current Season TOU Current Date TOU/ DmdLP Current Day Of Week (1-7 means Sun-Sat) TOU/DmdLP Current Time TOU/ DmdLP Time Remaining in Demand (Sub)interval in minutes (Not valid for thermal demands) All Real-Time Pricing time remaining until activation in min. All GE Energy GEH 7101 (11/07) 8 137

138 Exhibit GLK-2 Page 16 of Display Modes There are three display modes: Normal Alternate Test The user can switch between display modes using the display switch and the test switch Display Switch Actions The display switch is actuated using a magnet as shown in Figure 2-2. Holding a magnet next to the Display Switch for varying lengths of time causes the meter to change display modes: Less than 3 seconds: Restarts the Normal Display scroll, or produces one Normal Display scroll if an Error, Caution or Diagnostic is frozen on the display. More than 3 seconds: Enters the Alternate Display mode for one scroll then returns to the Normal Display mode. TIP: The magnetic end of the SMARTCOUPLER will activate the display switch Normal Display Mode In Normal Display mode, the meter display scrolls continually through the Normal Display items until one of the following occurs: Demand reset is invoked Display Switch is actuated Communication is initiated Test mode is invoked A frozen error or caution message is triggered. Note: The test mode push button is not accessible with the cover in place. Normal Display items are selected during program development using MeterMate software. The meter returns to the Normal Display mode when other display modes have completed or timedout. TIP: While the meter is communicating, the data annunciators are off and the LCD displays BUSY Alternate Display Mode The Alternate Display is used to display information for the meter technician that is not contained in the Normal Display. Display items: Selected during MeterMate program development Initiate: Actuate the display switch for more than 3 seconds Scroll: The meter automatically scrolls through the Alternate Display items Exit: The meter automatically returns to the Normal Display mode after the last Alternate Display item Test Mode Test mode is used to display data for testing the meter. Normal accumulation of billing data is suspended in test mode. Display Items: Selected during MeterMate program development. Initiate: Hold the test (T) switch for one second (requires removing the cover) or use MeterMate software commands. See Figure 2-3 for the location of the test switch. Figure 2-2: Alternate Display Mode Switch GE Energy GEH 7101 (11/07) 9 138

139 Exhibit GLK-2 Page 17 of 42 Scroll: Momentarily actuate the display switch to advance to the next item in the Test Display scroll Liquid Crystal Display Information Reset Accumulators: Hold the reset (R) switch to zero all accumulators and light all display segments. Test mode processing resumes when the reset switch is released. Pressing the reset switch does not affect billing data. Exit: Hold the test switch for one second or wait for the programmable test mode timeout period. Figure 2-4: Liquid Crystal Display Information 1. The TEST annunciator indicates the meter is in Test mode. 2. The ALT annunciator indicates the meter is in Alternate Display mode. 3. The three small digits are used to display the current display label or code. CA or Er appearing in this location indicates a Caution or Error message in the display. Figure 2-3: Reset and Test Switches Frozen Display Mode The Frozen Display mode stops the Normal Display to draw attention to an error, caution, or diagnostic in the meter. Display Items: Select errors, cautions and diagnostics to freeze the display during MeterMate program development. Initiate: Automatic when the meter detects a frozen error, caution or diagnostic. Scroll: Use a magnet to activate the display switch. The meter will perform one Normal Display scroll and then return to the Frozen Display. Exit: Clear the condition that caused the error, caution or diagnostic to return to the Normal Display mode. 4. These letters are used to display the units of measure for the quantity currently being displayed. For example, energy displays will have a kwh annunciator and Apparent Power will have a kva annunciator. 5. The letters A through D indicate the time-of-use (TOU) rate that is in effect. Only one letter at a time is displayed when the meter is operating in TOU Mode. If no letters are lit, the meter is in a non- TOU rate. 6. This display indicates an end-of-interval (EOI) condition. 7. When displayed, the A annunciator indicates the A voltage is present at the meter. If this annunciator is blinking, phase-a voltage is low. GE Energy GEH 7101 (11/07)

140 Exhibit GLK-2 Page 18 of 42 The B annunciator will only be displayed during an allsegments display. When displayed, the C annunciator indicates the C voltage is present at the meter. If this annunciator is blinking, C voltage is low (Network meters only.) Display Examples The following three figures show examples of possible I210+c meter displays kwh Display 8. The left-right arrows indicate watt-hour direction of energy flow. The right arrow will be lit if the energy is delivered; the left arrow will be lit if the energy is received. The up-down arrows indicate var-hour direction of quadergy flow. The up arrow will be lit if the quadergy is lagging; the down arrow will be lit if the quadergy is leading. The meter s magnitude indicator consists of three segments, used to simulate the rotation of the disk on an electromechanical meter. Each state change represents Kt. One complete revolution represents ten state changes, which represent Kh watt-hours or var-hours. The meter illuminates the segments as follows: State If the Wh direction is delivered (or the varh direction is lagging), the states change in increasing order with respect to the above illustration. If the Wh direction is received (or the varh direction is leading), the states change in decreasing order. Figure 2-5: kwh Display Figure 2-5 shows the following conditions: The Display Label is 01 Five-digit display of energy (kwh) Phase A voltage is present End-of-demand-interval indication. This indicator is lit at the end of each demand subinterval Displayed quantity is measured in kilowatt-hours Energy is being delivered to the load The one block indicates State 0 of the magnitude indicator Quadergy (kvarh) is lagging TOU rate B is in effect Note: If the calculated phasor VAh is below the configured creep threshold, the meter will turn off the Wh and varh direction arrows. 9. These characters display the programmed metering quantities. There are three possible decimal point positions located between the four rightmost digits. GE Energy GEH 7101 (11/07)

141 Exhibit GLK-2 Page 19 of Alternate Display Mode Figure 2-6: Alternate Display Figure 2-6 shows the following conditions: Meter is in Alternate Display mode Display label 108 is displayed Phase A and C voltages are present Six-digit display of quadergy (kvarh) Displayed quantity is measured in kvarh The two blocks indicate State 1 of the magnitude indicator Quadergy (kvarh) is leading Energy is being received from the load TOU rate A is in effect Test Mode Display Figure 2-7 shows the following conditions: Meter is in TEST mode Display label is 905 Meter display is a six-digit demand display (kw) with three digits to the right of the decimal point Phase A voltage is present Meter display is in watt-hours Energy is being delivered to the load Figure 2-7: Test Mode Display 3. Maintenance Instructions The information contained within this document is intended to be an aid to qualified metering personnel. It is not intended to replace the extensive training necessary to install or remove meters from service. Any work on or near energized meters, meter sockets, or other metering equipment presents the danger of electrical shock. All work on these products must be performed by qualified industrial electricians and metering specialists only. All work must be done in accordance with local utility safety practices and the procedures outlined in the current edition of the Handbook for Electricity Metering. The handbook is available from the Edison Electric Institute, 701 Pennsylvania Avenue N.W., Washington D.C Recommended Procedures The procedures described on the following pages are those recommended by the General Electric Company. Any procedures not described herein or referenced herein are not recommended Meter Testing Tools The meter is equipped with a light-emitting diode (LED) for calibration and a liquid crystal display with disk analog and test displays. The calibration LED is part of the ANSI Type 2 Optical port as shown in Figure 3-1. The three blocks indicate State 2 of the magnitude indicator Time-of-use metering rate D is in effect Quadergy (kvarh) is lagging Figure 3-1: Optical Port

142 Exhibit GLK-2 Page 20 of Calibration LED The optical port LED emits calibration pulses (infrared light) until the meter detects the presence of optical port PSEM communications. This LED is the source of watt-hour and var-hour calibration pulses. Each calibration pulse is equal to the value assigned to Kt (watt-hours or var-hours). The duration of each output pulse is approximately 25 milliseconds. The default unit for the calibration pulses is watt-hours. The meter may be switched to varh calibration pulses using MeterMate software LCD Display The meter display has annunciators for quadrant, phase voltage, and energy flow indication as shown in Figure 3-2. The annunciators provide valuable information during the testing process Starting the Test Mode To enter test mode, use the test switch on the face of the meter or MeterMate Meter Comm commands. Upon entering test mode, several actions occur: The current demand interval is terminated. All test accumulators are set to zero. The subinterval countdown timer starts. Load profile recording is suspended, and load profile interval status bits reflect test mode was in effect during affected interval(s). When test mode begins, the test annunciator is lit and the first item programmed for the test display is shown Operation During Test Mode The same summation quantities that are calculated during normal operation are calculated in test mode. The selection of quantities to be displayed in test mode is fully programmable in the MeterMate software. Watt-hour, var-hour, and volt-ampere-hour are displayed in units rather than kilo-units; i.e. the data is displayed as Wh, varh, and VAh rather than kwh, kvarh, and kvah. The same demand values calculated during normal operation are also calculated in test mode. The display formats for the demands are the same in test mode as they are in normal mode Energy Calculations If the metering constants are not programmed, default values are used. Table 3 1 contains the default test mode values. Table 3-1: Default Test Mode Values Figure 3-2: Liquid Crystal Display Refer to section for more information on these annunciators. Constant Demand decimal position Default Value XXX.XXX 3.2 Test Mode Number of demand subintervals 3 Test mode allows the meter to be tested without disturbing billing data or setting a new maximum demand. Test mode performs the same function as setting the pointers back on an electromechanical meter after testing. Demand subinterval length Energy display format 5 minutes XXX.XXX The display does not scroll while the meter is in test mode. Each Test mode may be entered by pressing the test switch for one second or by using MeterMate software commands. The test mode switch is operated by removing the Lexan cover and pushing the test switch. item remains displayed until the display switch is activated with a magnet. At that time, the next item in the display program is shown. The quantity displayed is updated every second. The test mode display is fully programmable. Table 3 2 lists the default test mode display items for an unprogrammed meter. Items can be added or deleted using MeterMate software. GE Energy GEH 7101 (11/07)

143 Exhibit GLK-2 Page 21 of 42 Table 3-2: Test Mode Default Display Display ID Display Quantity 94 Accumulating Wh 95 Previous interval kw demand 91 Time remaining in subinterval (MM SS) 92 Momentary interval demand 93 Maximum test kw demand Displays Available in Test Mode Only The following display items are available for display only in the test mode: Test mode maximum demands; Time remaining in test demand interval in block demand only; Time remaining in test demand subinterval in rolling demand only; Test mode summations; Test mode accumulating demand Test Reset A test reset is initiated by pressing the reset switch while the meter is in the test mode. A test mode reset causes all test quantities to be reset to zero and a new subinterval to be started. An all-segments display is shown until the reset switch is released. The item displayed when the reset occurred remains in the display, but the value will be initialized. In the event of a power outage, data for test mode energy and demand are not saved. These data are reset when power returns. Upon power-up, the meter remains in test mode and the item displayed when the outage occurs remains on the display. In a TOU meter or demand meter with load profiling, there may be a slight delay before re-entering test mode on power-up. During the delay, the meter is performing its catch-up tasks Exiting Test Mode Test mode is exited in one of three ways: 1. By pressing and holding the test switch for more than one second; 2. By an MMDOS or MMCOMM command; 3. By expiration of the test mode time-out timer. All test mode data is lost when test mode is exited. Upon exiting test mode in a meter programmed for rolling demand, the meter will start a new, possibly partial, subinterval. The past subinterval, as well as the current subinterval, is zeroed. Upon returning to the normal operating mode, a TOU meter or demand meter with load profiling will complete the time remaining in the current partial subinterval such that subsequent subintervals will be synchronized with the midnight boundary. The new subinterval in demand-only mode is the number of minutes remaining in the subinterval prior to entering test mode. For meters that are programmed for thermal emulation, the thermal demand reading is set to zero immediately after test mode is exited. The meter will automatically exit test mode when the time that the meter has been in test mode time has exceeded its programmed limit. This test mode time limit prevents accidentally leaving the meter in the test mode and losing billing information. The test mode time-out function is programmable from one minute to 99 hours. Note: Normal billing and load profile data accumulation is suspended during test mode operation. Upon exiting test mode accumulation of billing and load profile quantities will resume from the values in place when test mode was entered. 3.3 Field Accuracy Test Test mode allows the meter to be tested for accuracy in the field, without disturbing any billing data Field Testing with Test Mode Testing the meter in the field can be accomplished three ways in test mode by using the: 1. Maximum demand reading in the display; 2. Disk analog display; 3. Instantaneous demand feature of the I210+c Maximum Demand Reading Testing This is the most accurate of the three test methods. For this test, you need a portable standard with a start/stop switch and a phantom load. 1. Make sure that the voltage coils are in parallel and the current coils are in series. 2. Connect the phantom load and the portable standard to the meter to be tested. GE Energy GEH 7101 (11/07)

144 Exhibit GLK-2 Page 22 of Apply voltage to the meter and the standard and wait 20 seconds for settling time. 4. Put the meter into test mode. 5. Change the display to maximum demand (display ID 93 using the default display items). 6. Switch on the desired current. 7. Check the flow indicator on the meter to make sure that the polarity is correct. 8. Reset the standard. 9. Simultaneously reset the meter and start the standard. The test reset takes effect when switch is released. 10. Turn the current off when the end-of-interval (EOI) annunciator comes on. 11. Compare the meter readings with the standard s readings. EOI comes at the end of every subinterval; numbers won t match before interval is completed and display is updated. Where rolling demand is used (n sub intervals composing a complete demand interval) the display value needs to be multiplied by n for comparison to the standard value. 3.4 Disk Analog Testing The disk analog provides a precise means of checking the calibration of the meter. There are some practical limits to this method of testing. For example, if the load on the meter is very low, the test may take a long time. Conversely, if the load is high, it may be difficult to accurately time the switching of the standard. The disk analog in the I210 Demand/TOU works as follows: The meter s magnitude indicator consists of three segments, used to simulate the rotation of the disk on an electromechanical meter. Each state change represents Kt. One complete revolution represents 10 state changes, which represents Kh watthours or varhours. The meter illuminates the segments as follows: State If the Wh direction is delivered (or the varh direction is lagging), the state changes occur in increasing order. If the Wh direction is received (or the varh direction is leading), the state changes occur in decreasing order. For this test you need a portable standard with a start/stop switch. Field-testing using the disk analog allows you to check the calibration of the meter without having to install a phantom load. 1. Make sure the voltage coils are in parallel and the current coils are in series. 2. Connect the portable standard to the meter. 3. Reset the standard. 4. Observe the disk analog. Each cycle of the disk analog represents Kh watt-hours of accumulation. (The Kh value is printed on the meter nameplate.) 5. When the disk analog transitions from all segments on to all segments off, start the standard. 6. Let the disk analog scroll through a predetermined number of times (10, for example). 7. Stop the standard when the disk analog transitions from all segments on to all segments off the desired number of times. 8. Calculate the accumulated watt-hours as shown in Equation 3-1. Accumulated Energy = (Kh) (the number of complete disk analog cycles) Equation 3-1: Accumulated Watt-hours Calculation For example: if Kh equals 10 and 10 complete cycles were counted, then: 10 Wh x 10 complete scrolls = 100 Wh. 9. Compare the results of the calculation to the reading on the GE Energy GEH 7101 (11/07) standard.

145 Exhibit GLK-2 Page 23 of Shop Test Shop testing consists of verifying the meter s accuracy Meter Shop Equipment The meter loading equipment must be capable of maintaining accuracy while supplying energy to the meter s switching power supply. Otherwise, meters may be tested in any shop that meets the requirements outlined in the current editions of the Handbook for Electricity Metering published by the Edison Electric Institute and the American National Standard Code for Electricity Metering Equipment Setup The meter mounting equipment and its electrical connections must be used as required for the meter form number on the meter nameplate. If required for the test equipment used, the test link(s) must be opened Test Constant The meter test constant (Kt) is the number of watt-hours per calibration pulse. This value is printed on the meter label Watt-hour Test Procedure To test the meter, proceed as follows: 1. Note the meter Kt value listed on the nameplate. 2. Select the desired voltage and current level(s) on the test equipment. (Test voltage of 120V is assumed.) 3. Install the meter in the test socket, making certain that the socket is wired and/or configured for the appropriate meter form. 4. Align the optical pickup of the test equipment with the calibration LED. 5. Begin testing according to standard test procedures. Allow 15 seconds of settling time after applying voltage before making accuracy measurements. 6. Check the meter calibration under three load conditions: full load, light load, and full load with lagging power factor. A minimum test time of 30 seconds is needed to reduce test uncertainty. (Check the instruction book for your test board or standard to determine the actual minimum test time. Standards with heavily filtered inputs may require longer test times.) Var-hour Testing GE I210+c meters are digital sampling meters. All quantities are derived mathematically from the same set of voltage and current sample data used to compute watt-hours. Therefore, it is only necessary to check watt-hour calibration to ensure that all revenue quantities are accurate. However, some utilities are required by their public utilities commissions to verify the accuracy of var-hour data as well as watt-hour data. 1. Use MeterMate software to put the meter calibration LED into VArhour pulse output mode. 2. Set up the meter for testing as described above in the watt-hour test procedure. The test pulse value is now Kt var-hours per pulse. 3. Begin testing according to your standard var-hour test procedures. Allow 15 seconds of settling time after applying voltage before making accuracy measurements. NOTE: Test conditions with high power factors require very long varh test times. Typically varh testing is done at 120V and 0.5 PF. 3.6 Battery and Super Capacitor Replacement Lithium Inorganic 3.6 Volt Battery (Safety Precautions) Do not expose battery to temperatures above 100 degrees C. Do not incinerate, puncture, crush, recharge, short circuit and overdischarge battery. The contents are water reactive and the battery contents can form HCL (hydrochloric acid), SO 2 (sulfur dioxide) and H 2 (hydrogen), upon contact with water (only when forced open). Do not expose contents of battery to water. Do not expose contents to high humidity for extended periods of time. Dispose of batteries in accordance with local, state and federal hazardous waste regulations. To obtain an MSDS (Material Safety Data Sheet), contact your local GE supplier. Super Capacitor Safety Precautions Do not expose super capacitors to temperatures above 100 degrees C. Do not incinerate, puncture, crush, or disassemble super capacitors. Dispose of super capacitors in accordance with local, state and federal hazardous waste regulations GE Energy GEH 7101 (11/07)

146 Exhibit GLK-2 Page 24 of Replacing the Battery CAUTION: Battery and super capacitor installation must be done with NO power applied to the meter. 1. Read data from meter; 2. Remove power from the meter; 3. Remove the meter cover; 4. Disconnect the battery or super capacitor wire from the connector on the front of the nameplate carrier; 5. Grasp the front and back edges of the battery holder and squeeze them together; 6. Pull the battery holder out of the slot at the top of the nameplate carrier. 7. Remove the old battery; 8. Place the new battery in the battery holder; 9. Slip the battery holder into the slot at the top of the nameplate carrier and press down until the battery holder clicks into place; 10. Connect the battery wire to the nameplate carrier battery connector; 11. Replace the meter cover; 12. Energize the meter; 13. Reprogram meter; 14. Reset the Accumulated Outage Duration (time on battery backup) value using MMCOMM commands (Reset, Battery) Replacing the Super Capacitor The procedure for replacing the super capacitor, should that be necessary, is the same. It will take approximately 5 minutes for a super capacitor to fully charge. 3.7 Service The GE I210+c meter is factory-calibrated and requires no routine or scheduled service by the user. 3.8 Repair Factory repair or replacement service is offered when you cannot fix a problem. Because of the high density and integrated design, the repair of on-board components is not recommended. Instead, return the whole meter to General Electric as described in the following paragraph. 3.9 Returning a Meter If you wish to return a meter, call your General Electric sales representative for a Returned Material Authorization (RMA). The entire meter should be returned with the GE supplied Returned Material Authorization information form completed. Key information includes quantity, catalog number, serial number(s) and a complete description of the problem. Your General Electric sales representative will provide return instructions Cleaning CAUTION: Care must be taken during cleaning not to damage or contaminate any gold-plated contacts of the connectors. CAUTION: Do not immerse the meter in any liquid. Do not use abrasive cleaners on the Lexan covers. Do not use chlorinated hydrocarbon or ketone solvents on the covers Storage The I210+c meter is a durable device; however, it should be handled and stored with care. The temperature and humidity levels in storage are not critical, but extremes of either factor should be avoided Troubleshooting Guide The meter displays two types of codes: Error codes begin with Er and are shown in Table 3-3. Caution codes begin with CA and are shown in Table 3-4. Problems that do not cause any display codes are listed in Table Errors and Cautions The GE I210+c meter continually checks for internal errors, hardware failures, and cautions. These events are reported in coded form on the LCD Error Reporting The meter continuously checks its hardware components ROM, EEPROM, flash, battery, metering chip, and microprocessor to ensure that they are operating properly. When the meter detects that a hardware component is not operating properly, an error is reported. Error codes are displayed as soon as they are detected. The meter can be programmed to freeze error codes in the display when an error is detected. Refer to Table 3-3 for a list of errors. If subsequent tests indicate that the hardware component is operating properly, the meter will clear the error automatically. GE Energy GEH 7101 (11/07)

147 Exhibit GLK-2 Page 25 of 42 Table 3-3: Error Code Display Error Display Probable Cause Remedy Er Power outage occurred, and: a. Battery disconnected. b. Battery defective. Er Hardware failure a. Check for proper installation. b. Check for proper grounding. c. Call for factory assistance Er Non-volatile memory a. Check for proper data error installation. b. Check for proper grounding. c. Call for factory assistance Er Firmware ROM code error Replace meter. Er Meter Chip error Replace meter. Errors are serious events and usually indicate a condition has occurred that may have compromised the meter data. Unless GE has issued a service advisory indicating that other actions should be taken, you should remove the meter from service and contact your GE sales representative. The only exception to this rule is the Battery Failure & Power Loss error display, Er Do not return meters displaying Er The Er display indicates that the meter lost time during a power outage because of a weak, missing, disconnected, or defective battery. Replace the battery and set the meter s date and time to resolve this problem. If the meter has load profile data, the load profile recording function must be restarted. Be sure to read the meter s load profile data before doing this. TIP: When the meter is read through the optical port, error and caution conditions are returned with the meter data regardless of what display options are chosen in the meter program. Set meter s date and time, read meter s load profile data and restart load profile recording (if applicable), and: a. Connect battery. b. Replace battery Er Battery Failure & Power Outage The Battery Failure & Power Outage error indicates that the battery failed to maintain power during an outage. The meter has reverted to a demand mode of operation. The meter will increment only billing summation, and maximum demand values upon energizing the meter after loss of date/time information. It will update these values for the overall quantities and the programmed default TOU rate. TOU operations are suspended. Load profile data accumulated prior to the loss of date/time information is stored in non-volatile memory. TOU and load profile data is available for reading via the optical port or remote communication link. The battery should be replaced after reading the meter electronically to extract the data. The time and date should be programmed to resume proper TOU operations. The load profile function must be restarted to restore load profile operations. The meter can stay in service. Date & Time: Lost Load Profile recording: Stopped Register Function: Remains TOU, but operates as a demand meter with a default TOU rate Program: OK TOU schedule: Stopped TOU calendar: Stopped Billing Data: Total summations and max. Demands are OK (rolling billing period demand if enabled will cease, and traditional demand will begin); summations and demands for the programmed default TOU rate will also be updated Er Hardware Failure The Hardware Failure error indicates that the meter detected an internal hardware failure. The meter should be taken out of service and returned to GE. Date & Time: Stopped Load Profile recording: Stopped Register Function: Demand Only Program: OK TOU schedule: Stopped TOU calendar: Stopped Billing Data: May be corrupt GE Energy GEH 7101 (11/07)

148 Exhibit GLK-2 Page 26 of Er Non-volatile Data Error The Non-volatile Data error indicates a failure in the memory used to store configuration information, billing data, self-reads, event logs and load profile data. When the meter is not communicating, it continually tests the integrity of the data stored in non-volatile memory. If the meter detects an error in the non-volatile data, it sets the Non-volatile Data error. If subsequent tests pass, the error is cleared. A meter with a persistent Non-volatile Data error should be removed from service and returned to GE. Date & Time: Load Profile recording: Register Function: Program: TOU schedule: TOU calendar: Billing Data: OK May be corrupt Unchanged May be corrupt May be corrupt May be corrupt May be corrupt Er Firmware Code Error The Firmware Code error indicates a failure in the memory used to store firmware. When the meter is not communicating, it continually tests the integrity of the firmware stored in memory. If the meter detects an error in the firmware, the meter sets Firmware Code error. If subsequent tests pass, the error is cleared. A meter with a Firmware Code error should be removed from Table 3-4: Caution Code Display service and returned to GE. Date & Time: Load Profile recording: Register Function: Program: TOU schedule: TOU calendar: Billing Data: OK? OK? Unchanged OK? OK? OK? OK? Er Meter Chip Error The Meter Chip error indicates the meter has detected an error in the operation of its meter chip. If subsequent correct operation occurs, the error is cleared. A meter with a persistent Meter Chip error should be taken out of service and returned to GE. Date & Time: Load Profile recording: Register Function: Program: TOU schedule: TOU calendar: Billing Data: OK? Corrupt data Unchanged OK OK OK Caution Reporting Corrupt data The meter also checks other conditions that are of concern but do not indicate a problem with the meter hardware. The meter reports these as cautions. Individual cautions may be enabled or disabled selectively. If a caution is enabled, it can be configured to be displayed and optionally freeze the display. Caution Display Probable Cause Remedy CA Low battery. Battery failed test. Replace battery. CA Meter unprogrammed. Using default values. Program the meter. CA Loss of program. Programming interrupted. Program the meter. Using previous values. CA Loss of program and Meter is unprogrammed. Program the meter. Programming interrupted, Using default values. CA DC detected Investigate cause of DC component. CA Low potential on phase A. Check circuit voltage. CA DC detected and Low potential. Check circuit voltage. Investigate cause of DC component. CA Demand overload warning has exceeded Check for service overload conditions. programmed threshold. Check programming threshold value. CA Leading kvarh warning. a. Disable the warning. b. Check system operating parameters if leading kvarh is unexpected. CA Received kwh warning. a. CT polarity is incorrect a. Check meter socket and CT wiring. b. Energy is flowing from load to line. b. Disable caution. Check system operating parameters c. Meter s internal wiring defective if reverse energy flow is unexpected. c. Check that sensor connector is properly seated

149 Exhibit GLK-2 Page 27 of 42 Low battery, loss of program and unprogrammed cautions are used to remind the user of actions that are required. Any meter with a low battery caution may lose time if the battery is not replaced before the next power outage. Other caution codes report unusual operation such as receiving energy from the load, leading power factor, very high current flow, or low voltage. TIP: When multiple cautions occur they are combined. For example, CA indicates leading quadergy and low potential CA Low Battery The Low Battery caution indicates a weak or missing battery. The meter periodically tests the battery. The meter sets the Low Battery caution if the battery voltage is low. The Low Battery caution is cleared when the battery test passes. The meter tests the battery under the following conditions: Power up 1st of each month (00:16) Activation of the Display Switch (not in Test Mode) MeterMate Meter Communication command CA Unprogrammed The Unprogrammed caution indicates that the meter is not programmed and is functioning in a default demand mode. The meter is shipped unprogrammed unless it is ordered factory-programmed. The MeterMate Meter Communications Unprogram command will put the meter into the Default Demand mode and set the Unprogrammed caution. Programming the meter clears the Unprogrammed caution CA Loss of Program The Loss of Program caution indicates that a programming session was interrupted. The meter sets the Loss of Program caution when a programming session is terminated abnormally. The meter will roll back to the last good program and operate from it. If a meter has a Loss of Program caution, reprogram the meter and the Loss of Program caution will be cleared CA Unprogrammed and Loss of Program The Unprogrammed and Loss of Program caution indicates that a programming session was interrupted while the meter was operating in default demand mode. The meter sets the Loss of Program caution when a programming session is terminated GE Energy GEH 7101 (11/07) abnormally. The meter will roll back to the default demand program and operate from it. If a meter has an Unprogrammed and Loss of Program caution, reprogram the meter and the Unprogrammed and Loss of Program caution will be cleared CA DC Detected The DC Detected caution indicates the presence of DC in the current signal. The meter checks for the presence of DC every second; if it detects the presence of DC for longer than the factory configured duration, the meter sets the DC Detected caution. The meter does not automatically clear the DC Detected caution. The DC Detected caution is cleared by a demand reset CA Low Potential The Low Potential caution indicates that measured voltage falls below the programmed tolerance. The voltage is tested every five seconds using the voltage from the previous second. The meter sets the Low Potential caution when the test fails three consecutive times. The meter automatically clears the Low Potential caution when all active phases exceed the minimum threshold for two consecutive tests CA DC Detected and Low Potential The DC Detected and Low Potential caution indicates that measured voltage fell below the programmed tolerance and the presence of DC in the current signal has been detected CA Demand Overload The Demand Overload caution indicates that the kw demand exceeded the programmed threshold. The meter compares the value of the instantaneous kw demand quantity to the programmed threshold every five seconds using the demand from the previous second. The meter sets the Demand Overload caution when the kw demand exceeds its threshold for 3 consecutive tests. The meter does not automatically clear the Demand Overload caution. The Demand Overload caution is cleared by a demand reset CA Leading kvarh The Leading kvarh caution indicates that the current leads the voltage instead of lagging it. The meter tests the direction of the quadergy every five seconds using the kvarh from the previous second. The meter sets the Leading kvarh caution when the direction of the quadergy is leading for three consecutive tests. The meter does not automatically clear the Leading kvarh caution. The Leading kvarh caution is cleared by a demand reset

150 Exhibit GLK-2 Page 28 of CA Received kwh The Received kwh caution indicates that active energy was received from the load. The meter tests the direction of the active energy every five seconds using the kwh from the previous second. The meter sets the Received kwh caution when the direction of the active energy is received for three consecutive tests. The meter does not automatically clear the Received kwh caution. The Received kwh caution is cleared by a demand reset. Table 3-5: Fault Symptoms Without Codes Symptom Probable Cause Remedy High/low demand registration Meter overheats Meter runs slow No display GE Energy GEH 7101 (11/07) a. Socket wiring error. b. Meter internal wiring defective. c. Defective sensor. a. Rewire according to applicable diagram. b. Check that voltage and current connectors are seated properly. Check the leads for damage. c. Replace meter. a. Meter socket has a. Replace mounting insufficient with a heavy duty capacity or is not model. adequately wired. b. Use transformer b. Meter is rated installation. overloaded. c. Replace socket c. Poor connection at terminal. socket terminal. a. Socket wiring error. b. Meter internal wiring defective. c. Defective sensor. a. Circuit de-energized. b. Test link(s) open. c. Meter internal wiring defective. a. Rewire according to applicable diagram. b. Check that voltage and current connectors are seated properly. Check the leads for damage. c. Replace meter. a. Check circuit voltages. b. Close test links. c. Check that the voltage and current sensors are properly connected. Also check the wires for damage. 4. Upgrading 4.1 General The GE I-210+c meter contains lethal voltages. The meter must be completely disconnected from any external circuits before disassembly is attempted. Failure to observe this practice can result in serious injury or death. Refer to the MeterMate software manuals (GEH-5082O, GEH- 5084O) for instructions on how to install and enable software options. 4.2 Soft-switches The basic I210+c meter provides a powerful platform for advanced metering. Features may be added to the basic meter through soft-switches, which enable built-in capabilities. Softswitches may be ordered at the time the meter is purchased, or added in the field. Soft-switches may be removed from one meter and installed in another meter. The following table lists the soft-switches available in the I210+c : Table 4-1: I210 Demand/TOU Soft-switches Switch Description A2 Alternate Communication E2 Event Log K2 kvar and kva measures N2 Billing Demand Q2 Voltage Measures R2 Load Profile Recording (two channels) T2 Time-of-use Alternate Communication A2 Soft-switch The Alternate Communication Soft-switch allows a communication option board to communicate with the meter Event Log E2 Soft-switch The Event Log Soft-switch allows the meter to track the most recent 200 events. Use MeterMate Program Manager, Diagnostics Editor, to select the event types to be logged and how many occurrences should be tracked, up to a maximum of 200 events. Date and time stamps are included on logged events for Demand/LP or TOU meters. Logged events include: Cautions: Low potential, demand overload, leading kvarh, reverse energy flow, DC detection (set and clear events);

151 Exhibit GLK-2 Page 29 of 42 Real-time pricing activation and deactivation; Test mode activation and deactivation; Externally initiated meter reading (local or remote); Programming sessions; Power up, power down; Demand resets; Self-reads kva and kvar Measurements K2 Soft-switch The kva and kvar Soft-switch adds kva(h) and kvar(h) measurement capability. The K2 Soft-switch enables the following configurations for varh measurements. Fundamental plus harmonics varh lagging only Fundamental plus harmonics varh leading only Fundamental plus harmonics varh lagging - leading Fundamental plus harmonics varh lagging + leading The K2 Soft-switch enables Fundamental plus harmonics Phasor Apparent VAh measurement. The I210+c meter can have up to two quantities defined in the measurement profile, with each of these being used for summations and demands Demand N2 Soft-switch The Demand (N2) Soft-switch adds billing demand calculations. If the N2 switch is not present, the meter will not calculate billing demands and will set demands to 0 (zero). The meter will always calculate non-billing demands for cautions Power Quality Measurements Q2 Soft-switch The Power Quality Measurements Soft-switch enables the following: Voltage (L-N): VA (max, min, store) for summations, demand, and load profile recording; RMS voltage measurement for reading and display; Low potential caution Basic Recording R2 Soft-switch The Basic Recording Soft-switch enables up to two channels of load profile recording. The number of active channels and days of load profile data are configurable using the MeterMate Program Manager Recorder Option editor Time Of Use T2 Soft-switch The Time-of-use Soft-switch enables TOU operation. The meter supports: Up to four TOU periods and four Seasons Up to three daily rate schedule types and one holiday schedule Up to 80 TOU schedule set points Up to 50 programmable dates: Holidays, season changes, Daylight Savings Time (DST), self-read, demand reset Perpetual calendar handles most dates Up to two billing and two demand measures per TOU period Self-read actions on specified dates, with or without a demand reset 4.3 Converting from Demand to Demand/LP or TOU Mode The I210+c is four meters in one: demand, demand/load profile, TOU and TOU/load profile. The load profile recording and time-ofuse options require soft-switches to extend the functionality of the basic demand meter. The following items are required to enable demand/lp, TOU or TOU/LP operation: Computer with MeterMate software; Soft-switch holder with T2, and R2 switches SMARTCOUPLER device Timekeeping battery or super capacitor If at any time you are unsure if the meter has been upgraded, select Check Meter on the MeterMate Upgrade menu. The screen will display the capabilities of the meter. To enable the TOU function, proceed as follows: CAUTION: Battery installation must be done with NO power applied to the meter. GE Energy GEH 7101 (11/07)

152 Exhibit GLK-2 Page 30 of Plug the soft-switch holder into the parallel port or USB port of the computer. 2. Install and connect the battery. See section 0, Battery Replacement. 3. Apply power to the meter. 4. Connect the SMARTCOUPLER device to the serial port of the computer and the optical port on the I210+c Meter. 5. Using MeterMate Meter Comm software, go to the menu bar. 6. On the menu bar, select Upgrade. 7. On the Upgrade menu, select TOU. 8. This enables the TOU function in the meter. When the upgrade has completed, MeterMate returns to the Upgrade menu. 9. Mark the TOU box on the nameplate. 10. Repeat steps 8 through 10 for the Basic Recording, R2 Soft-switch. TIP: If you are not ready to install the TOU program, the meter may still be used as a Demand meter after the TOU switch is enabled. The battery may be put in place in the battery holder, but must not be connected until the meter has been programmed for TOU operation Removing the Meter Cover Remove the meter cover as follows: 1. Remove the seal from the right side of the meter. If there is no seal, proceed to the next step. 2. Turn the cover counterclockwise approximately 30 degrees. 3. Lift the cover straight up Removing the Electronics Module To remove the electronics module, follow the instructions below: 1. Disconnect the CT connector from the socket on the electronics module. 2. Grasp the snaps on either side of the nameplate carrier between the thumb and index finger and press them together to release them from the notches on the base posts. It may be easier to unclip one side at a time. Ensure that all four snaps are disengaged and lift the module assembly off the base. 3. Place the module on a flat, clean, cloth-covered surface with meter face down. CAUTION: Do not pull on the wires to disengage the connectors. Pull only on the connectors. 4.4 Meter Disassembly The GE I210+c meter contains lethal voltages. The meter must be completely disconnected from any external circuits before disassembly is attempted. Failure to observe this practice can result in serious injury or death. CAUTION: Do not interchange base and electronics module assemblies between meters. Calibration data stored in the meter is particular to a set of current sensors and electronics module. Interchanging these components causes the meter to lose calibration. The meter is disassembled in steps. First, remove the meter cover. Second, remove the electronics module from the base. GE Energy GEH 7101 (11/07)

153 Exhibit GLK-2 Page 31 of 42 Figure 4-1: Exploded View of I210+c Meter 4.5 Meter Reassembly 1. Carefully align the module over base assembly posts and push down firmly to engage all four snaps on the post undercuts. 2. Connect the CT sensor connector to the socket on the electronics module. 3. Replace the cover by aligning it with the openings in the base and rotating it clockwise approximately 30 degrees. 5. Site Guides NOTICE: The site information includes rudimentary connection diagrams. These diagrams are not metering installation guides. The PHASOR diagrams are shown for informational purposes only. The meter does not provide the information necessary to determine the phase relationships between voltages and currents. 4. Install security seals as required. GE Energy GEH 7101 (11/07)

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162 Exhibit GLK-2 Page 40 of Diagrams Figure 6-1: ANSI Meter Diagrams GE Energy GEH 7101 (04/07)

163 Exhibit GLK-2 Page 41 of

164 Exhibit GLK-2 Page 42 of , General Electric Company. All rights reserved. GEH-7101 (11/07) 164

165 Exhibit GLK-3 Filed Highly Confidential and Highly Sensitive 165

166 Exhibit GLK-4 Page 1 of 1 TEXAS-NEW MEXICO POWER COMPANY Exhibit GLK-4 APPROXIMATE COVERAGE CALCULATIONS AS OF MARCH 25, 2010 City Deployment Location Number of Non-Com Points Eliasville North Texas 147 Fort Stockton West Texas 568 Gatesville Central Texas 3 Gordon Central Texas 4 Graham North Texas 11 Jean North Texas 30 Loving North Texas 61 Newcastle North Texas 3 Nocona North Texas 4 Olney North Texas 183 Saint Jo North Texas 1 Sanderson West Texas 13 Strawn Central Texas 2 Valley Mills Central Texas 1 Total 1031 Deployment Location Number of Non-Com Points Total Points Total Coverage Gulf Coast 119, % Lewisville 40, % North Texas ,326 98% Central Texas 10 25, % West Texas ,301 96% , % 166

167 Exhibit GLK-5 Page 1 of 31 WEBINAR Briefing on AT&T Network Disaster Recovery Robert Desiato, Director Network Disaster Recovery AT&T Global Network Operations AT&T Intellectual Property. All rights reserved. AT&T, AT&T logo and all other marks contained herein are trademarks of AT&T Intellectual Property and/or AT&T affiliated companies.

168 Global Network Operations Mission Exhibit GLK-5 Page 2 of 31 Ensure that the AT&T Global Network always connects people with their world everywhere they live and work and does it better than anyone else Provide Comprehensive and Seamless Customer Application Service Quality, by preventing, detecting and correcting failures in the network before they impact the service experience. 168 Page AT&T Intellectual Property. All rights reserved.

169 MPLS nodes serving Around the world Hundreds of Thousands of backbone fiber Miles worldwide Millions of Wireless Customers Wi-Fi hot spots around the world In the 2Q of 09 AT&T handled over 100 Billion Text messages 24x7x365 Network monitoring & management Network Scale and Scope Industry Leader Leaders Quadrant Global, Pan European, US, Asia Pacific Network Service Provider, Web Hosting, IP Conferencing and Wireless Service (Gartner surveys, 2006 through 2009) Leader in Global Networking for Multi Nationals (IDC 12/2008) Most Complete footprint for enterprise managed service contracts of top 5 global providers (Ovum 1/2009) US Enterprise Telecom Leader (Oct 2008) MPLS North American Leader (Forrester 10/2008) Best in Class World's Most Admired Telecommunications Company, Fortune Magazine ( ) Highest Customer Satisfaction among large business customers of local telephone service (J.D. Power and Associates, 2008) Exhibit GLK-5 Page 3 of % Fortune 1000 companies are AT&T customers Thousands of Major network buildings and many thousand of satellite locations Millions of Access and Broadband Lines Millions of Video and U-Verse customers, Petabytes of data handled each day Internet Data Centers around the world 169 Page AT&T Intellectual Property. All rights reserved.

170 Securing Our Network Exhibit GLK-5 Page 4 of 31 NETWORK RISKS Ike 2008 Am I Ready? Are You Ready Are We Ready? PHYSICAL LOGICAL ECONOMIC POLITICAL SOCIAL 170 Page AT&T Intellectual Property. All rights reserved.

171 AT&T Network Survivability Protocol Exhibit GLK-5 Page 5 of 31 Survivability built in layers Disaster Recovery Intelligent Routing, Failure Analysis Network Disaster Recovery Manual Repair, if necessary. Automatic Reconfiguration Automation Isolation and Root Cause Correlation. Transport Equipment Restoration & Resilience, Physical Diversity of Fiber Intelligent Monitoring Rigorous Pre-deployment Testing. Network Designed for Resiliency from the Ground Up. 171 Page AT&T Intellectual Property. All rights reserved.

172 AT&T Post-Mergers Better Response Capability Exhibit GLK-5 Page 6 of 31 AT&T is positioned with phenomenal scale and depth of Resources and Technology available to apply to Network Recovery and Restoration. Pre-Mergers Current State Independent preparation, processes, assets, people and response to events Integrated preparation, processes, assets, people and response to events AT&T SBC BLS CING AT&T 172 Page AT&T Intellectual Property. All rights reserved.

173 AT&T Network Continuity Best Practices Exhibit GLK-5 Page 7 of 31 Plans Personnel Process Practice Practice Practice Practice Monitor & Manage Events Respond, Resume, Recover, Restore Learn 173 Page AT&T Intellectual Property. All rights reserved.

174 AT&T NDR Field Exercises Exhibit GLK-5 Page 8 of 31 The NDR team has conducted field exercises three or four times a year since its formation in The exercises test as many of the NDR processes as possible, from the initial call-out, to equipment transportation and setup, to technology turn-up and testing. At these exercises, team members are given hands-on training on new technologies and the recovery equipment is operated in field conditions. The drills are held throughout the United States in a wide variety of weather and settings and using a variety of recovery scenarios. NDR s 2010 exercise schedule: Dates are for Employee Day, Customer Day New Orleans 3/16, 3/17 Detroit/Dearborn 5/11, 5/12, 5/13 San Francisco (proposed) 7/3, 7/14 Philadelphia (Proposed) 10/19, 10/ Page AT&T Intellectual Property. All rights reserved.

175 AT&T Network Disaster Recovery Exhibit GLK-5 Page 9 of 31 Support Infrastructure 175 Page AT&T Intellectual Property. All rights reserved.

176 AT&T Network Disaster Recovery Exhibit GLK-5 Page 10 of 31 Theodore Vail Dedicated Teamwork Well-practiced and tested team of telecom disaster recovery professionals supplemented by a large pool of volunteers who train together during quarterly field exercises. 176 Page AT&T Intellectual Property. All rights reserved.

177 AT&T Network Disaster Recovery Exhibit GLK-5 Page 11 of 31 Hazardous Material Response 177 Page AT&T Intellectual Property. All rights reserved.

178 AT&T Network Disaster Recovery Exhibit GLK-5 Page 12 of 31 MOW Recovery Equipment AGN 178 Page AT&T Intellectual Property. All rights reserved.

179 AT&T Network Disaster Recovery Exhibit GLK-5 Page 13 of 31 Specially Designed Recovery Equipment Continue to invest in our Disaster Recovery Equipment including, Technology, Infrastructure and Support Elements 179 Page AT&T Intellectual Property. All rights reserved.

180 AT&T Network Disaster Recovery Exhibit GLK-5 Page 14 of 31 Recovery Technology Trailers 180 Page AT&T Intellectual Property. All rights reserved.

181 AT&T Network Disaster Recovery Exhibit GLK-5 Page 15 of 31 Power & Infrastructure 181 Page AT&T Intellectual Property. All rights reserved.

182 AT&T Network Disaster Recovery Exhibit GLK-5 Page 16 of 31 Command Centers Emergency Communications 182 Page AT&T Intellectual Property. All rights reserved.

183 Satellite COLTS Exhibit GLK-5 Page 17 of 31 The Network Disaster Recovery Team has the ability to provide satellite-based cell communications during disaster recovery and special situations. This capability is provided by two platforms: Cell-on-Wheels (COW) and Cellon-Light Truck (COLT). 183 Page AT&T Intellectual Property. All rights reserved.

184 Emergency Communications Vehicle (ECV) Exhibit GLK-5 Page 18 of 31 NDR satellite connectivity for voice over IP and data, which can be deployed when traditional connectivity to the AT&T Network is not available. 184 Page AT&T Intellectual Property. All rights reserved.

185 Emergency Communications Vehicle/Command Center Exhibit GLK-5 Page 19 of 31 NDR satellite connectivity for voice over IP and data, which can be deployed when traditional connectivity to the AT&T Network is not available. This equipment also provides workspace for up to four personnel. 185 Page AT&T Intellectual Property. All rights reserved.

186 AT&T 3CP Command, Control, Communications Exhibit GLK-5 Page 20 of Page AT&T Intellectual Property. All rights reserved.

187 Pro-Active Preventive Exhibit GLK-5 Page 21 of 31 High Profile Events U.S. Presidential Inauguration Hurricane Preparedness High Profile Events 2008 European Football Championships Switzerland & Austria 2008 Olympics in Beijing 187 Page AT&T Intellectual Property. All rights reserved.

188 Exhibit GLK-5 Page 22 of 31 Examples of AT&T NDR Deployments 188 Page AT&T Intellectual Property. All rights reserved.

189 Exhibit GLK-5 Page 23 of 31 May 2009 WV National Guard Flood Response 189 Page AT&T Intellectual Property. All rights reserved.

190 Hurricane Ike September 2008 Exhibit GLK-5 Page 24 of Page AT&T Intellectual Property. All rights reserved.

191 Hurricane Ike - September 2008 Exhibit GLK-5 Page 25 of Page AT&T Intellectual Property. All rights reserved.

192 Hurricane Ike September 2008 Exhibit GLK-5 Page 26 of 31 Satellite COLT at UTMB Hospital in Galveston, TX Network office recovery on Galveston Island Satellite COLT at on the Bolivar Peninsula, east of Galveston Island 192 Page AT&T Intellectual Property. All rights reserved.

193 Hurricane Katrina s Local/Wireless Impact Exhibit GLK Page 27 of 31 Switch Decommissioned 193 Page AT&T Intellectual Property. All rights reserved.

194 September 11, 2001 New York City Exhibit GLK-5 Page 28 of 31 AT&T transport node in the 6 th sub-basement of the World Trade Center s South Tower was totally destroyed Network Call Attempts reached a high of 431M, 30% higher than the previous of 330M. 194 Page AT&T Intellectual Property. All rights reserved.

195 September 11, 2001 WTC Response Simultaneous Recovery/Restoration of the Destroyed Office & Support of Authorities Exhibit GLK-5 Page 29 of 31 Emergency Communications Vehicle 1 Police Plaza, New York City NDR Recovery Site for NYC/WTC Local Services Jersey City, NJ 195 Page AT&T Intellectual Property. All rights reserved.

196 AT&T Always Prepared & Ever Vigilant Exhibit GLK-5 Page 30 of 31 Industry Leader Global Network Scale Integrated Shared NDR Assets Integrating Operations History of Successful Execution Extended Capabilities History and Habit of Investment Unrivaled Talent Anytime Anywhere Any Event 196 Page AT&T Intellectual Property. All rights reserved.

197 Thank You! Exhibit GLK-5 Page 31 of 31 Robert Desiato Director, Network Disaster Recovery (908) (Office) (908) (Cell) 197 Page AT&T Intellectual Property. All rights reserved.